The European Recycling Industries’ Confederation (EuRIC) is issuing a stark warning to European policymakers as current waste shipment proposals both risk significant job losses and hampering investment in Europe’s pioneering circular economy sector.

European recyclers already contribute 95 billion EUR in turnover to Europe’s already fragile economy. Yet up 80% of metal and paper recyclers anticipate a reduction in turnover under current waste shipment proposals. More than 300,000 EU green jobs are sustained by the sector, yet up to 50% of metal and paper recyclers warn that job losses will be inevitable.

“Policymakers have a choice. Are they on the same side as a sector at the forefront of championing a European circular economy? Or do they want to encourage the extraction of raw materials over recycling? Waste shipment rules must change course to encourage free, fair and sustainable trade of recycled materials” warned Emmanuel Katrakis, Secretary General of EuRIC.

The industry supports waste shipment restrictions that discourage exports of “problematic” waste outside the EU such as mixed plastic, unprocessed tyres, batteries and vehicules. However, it is concerned that current proposals incentivise extraction of raw materials, which is a significant source of pollution, over recycling. Not only will this hinder Europe’s ability achieve its recycling and net-zero emissions targets, but green job losses will also be unavoidable and investment in Europe’s circular economy will be significantly curtailed.

The European Recycling Industries’ Confederation (EuRIC) strongly rejects an EU proposal that will indirectly ban materials from tyres as part of its effort to eradicate microplastics.

Each year around 150 million tyres are processed for recycling annually – that’s one tyre for every three EU citizens. This rubber from recycled tyres has a wide range of everyday benefits that may not always be obvious – including essential materials for artificial football pitches, children’s playgrounds, and filling potholes. “Under the current proposal more than 50,000,0000 unrecycled tyres may pile up or are at risk of being exported outside the EU for incineration where environmental standards are less stringent. A one-size-fits-all approach is not the smart climate policy that we expect from the EU,” says Emmanuel Katrakis, Secretary General of EuRIC.

23 June 2022

EuRIC and ETRMA are pleased to see rubber recycled from end-of-life tyres among the “top 3” most suitable candidate streams for which to develop further EU-wide end-of-waste (EoW) criteria but further policy makers’ commitment is needed.

Brussels, 13 May 2022 – The proposal to revise the Waste Shipment Regulation (WSR) requires substantial improvements to deliver on its key objectives, namely combat illegal shipments while boosting circular value chains. The one-size-fits all approach subjecting all waste streams to similar export restrictions without making any distinction between untreated and raw materials from recycling (RMR) meeting quality specifications, will result in lasting negative impacts for the EU’s recycling industry. In particular, metal scrap from mechanical recycling should not be subject to export restrictions from the EU. If kept, such restrictions would result in substantial leakage of the recycling capacity to outside Europe. There would be resultant job losses in one of the most dynamic and circular industries. They would also deter business from scaling-up capacities and investing in new technologies to deliver raw materials that the European – and wider – industry needs. In turn, this would significantly hamper an EU circular and climate-neutral economy.

Adopted in June 2019, the recast Regulation on Persistent Organic Pollutants (POPs) set the contaminant limits that largely determine the treatment of the waste and, in particular for limits in Annex IV, define whether a waste containing specific POP substances should be disposed of in such a way that the POP content is destroyed or irreversibly transformed or whether it can be subjected to other recovery or disposal operations, including recycling.

The entry concerning PBDEs (including DecaBDE) in Annex IV contains a clause requiring the EU Commission (hereinafter the Commission) to review the Low POP Concentration Limit (LPCL) for these substances by 16 July 2021. The limit value for the substances is currently set at 1,000 mg/kg. The Commission was asked to look at the feasibility of reducing the aforementioned value to 500 mg/kg as finally published on 28 October 2021.

The signatory organisations to this position paper acknowledge the challenge set out by the Commission and believe that the discussion and decision around any revision of the LPCL for PBDEs needs to be based on current scientific knowledge and the factual situation concerning the sound waste management and treatment of POP containing materials in the electrical, electronic and automotive sectors in the EU.