Position papers
Over the last decades, the European recycling industries have drastically evolved by modernizing and constantly innovating to turn more waste streams into new resources. By doing so, the sector has contributed to the development of new technologies and automated equipment made in Europe and exported around the globe. The European regulatory framework has accompanied these changes thanks to ambitious targets and a meaningful waste hierarchy. However, the recycling sector continues to be subject to a complex and ever-growing EU regulatory framework, which affects its activities. To ensure a competitive European recycling sector, which is part of a global industry, EuRIC advocates clear, effective and smart European policies which:
- Incentivise recycling across the value chains;
- Minimise regulatory burdens on recyclers, in particular on SMEs;
- Guarantee an open and fair competition within Europe and with the world to foster a genuine internal recycling market.
EuRIC also advocates positive measures to ensure a consistent implementation of existing legislation across Europe.
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Press Release | Clothing reuse has a 70 times lower environmental impact reveals new study
A new life-cycle assessment (LCA) commissioned by the European textile reuse and recycling industry has confirmed the significant CO2 and water savings of reusing textiles compared to producing new clothing. The environmental impact of reusing textiles is 70 times lower, even when accounting for global exports for reuse including transport emissions.
More specifically, the study revealed that a massive 3kg of CO2 is saved for each high/medium-quality clothing that is reused. While only a mere 0.01% of the water used to produce new clothing is required for reuse. These results come on the back of the EU launching its Strategy for Sustainable Textiles just a few months ago and requirements for Member States to start collecting textiles separately by 2025.
While the study confirms waste hierarchy assumptions on the environmental benefits of reuse over recycling, in the case of low-quality clothing, typically entirely composed of polyester, recycling also has comparative environmental benefits when consumers are less likely to purchase second-hand clothing.
“Regrettably, around 62% of used clothing and textiles end up in household waste meaning valuable textiles are likely to be incinerated or landfilled. The European textile reuse and recycling industry envisages a circular textile value chain where every piece of clothing is reused in an optimal way and/or recycled,” says Mariska Boer, President of EuRIC Textiles. “This study endorses the environmental benefits of a global market for textile reuse and recycling’s potential to tackle the rising amounts of low-quality and non-reusable clothing,” she added.
The study also emphasised recommendations to policymakers, calling for initiatives that accelerate investments in state-of-the-art textile recycling facilities globally. In particular, innovation in fibre-to-fibre recycling will be key to keep textile fibres in the loop as volumes of non-reusable clothing are set to dramatically increase. The study also notes the importance of eco-design criteria that enhance the lifespan of clothing before there is a need for recycling as well as rules that mandate detailed sorting of high/medium-quality and low-quality textiles.
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Study | LCA-based assessment of the management of European used textiles
The study provides a qualitative overview of the market surrounding used textiles both in Europe and
globally. This includes a presentation of current and future collection and sorting practices in Europe, the
share and fate of various qualities, including both reuse and recycling, and projected volumes, fates and
composition of collected textiles post 2025. Then, the two comparative lifecycle assessments are presented.
First, the LCA of imported new garments vs imported second-hand garments, and then the LCA comparison
of exported reused textiles vs. recycling in Europe. Each LCA includes the following parts: 1) Goal and scope,
2) Life cycle inventory analysis, 3) Life cycle impact assessment, 4) Interpretation, 5) Limitations and 6)
Conclusion. Lastly, the report presents a set of recommendations based on the findings.The lifecycle impact assessment of reuse compared to a new product confirms that the environmental
impact of reuse is significantly lower than the production of a new garment, for all three qualities. For both
the crème and the B-grade t-shirt, the new garment is responsible for almost 70 times more overall
environmental impact than a reused t-shirt, and in terms of CO2-equivalents, the reuse of both types of
garments saves more than 3 kg CO2. The impact from a new garment primarily comes from the production
of fibres as well as the production in itself, whereas the little impact connected with reuse comes from
transportation to point of sales. But the latter is comparably trivial to the impact of the production of a new
garment, that the study supports the existence of a global market for reuse, despite the connected
transportation. -
Press Release | European Parliament backs waste shipment restrictions undermining certainty for recyclers
Europe’s recycling industries expressed dismay at the European Parliament’s adoption of current waste shipment proposals citing major inconsistencies undermining the trade of recycled materials. While the establishment of mandatory recycled content targets for plastics should be applauded[1], the failure to consider targets for metals and paper is a significant omission that will erode demand and subsequently green investment in new and upscaled recycling facilities in Europe.
However, European recyclers were encouraged by the European Parliament’s support of existing proposals that facilitate the export of recycled materials within the EU, such as establishing English as the common language or extended time limits for receiving shipments. Nevertheless, the lack of harmonised end-of-waste criteria and rules that allow Member States to reject shipments will continue to impede a functioning single market for recycled materials in Europe.
Moreover, the Parliament has regrettably reinforced a one-size-fits-all approach to export restrictions. This means that the same restrictions apply to low-quality mixed plastic waste as for high-value raw materials from recycling for which access to European and international markets is essential to preserve the competitiveness of the European recycling industry. By failing to make this distinction, up to 80% of metals and paper recyclers expect losses in turnover, and up to 50% expect job losses.
“Recycled materials already struggle to compete with extracted raw materials. If current waste shipment proposals are adopted, this will be yet another major setback for Europe’s recycling industries and our climate ambitions,” noted Emmanuel Katrakis, Secretary General of the European Recycling Industries’ Confederation (EuRIC). “If the EU wants a vibrant recycling industry that leads the circular economy transition and reinvests in Europe, it must establish rules that accelerate rather than impede demand for recycled materials. Member States must now act swiftly to address our concerns or risk unprecedented levels of incineration and massive stockpiling of valuable resources in landfill,” he added.
[1] You can consult the EuRIC letter to European policymakers specifically addressing the issue of a plastic export ban here.
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Letter | European Parliament ban on plastic exports to significantly impair European plastic recycling unless complementary measures are taken
The European Parliament adopted a resolution on 17 January 2023 on the Commission’s proposal for a Waste Shipment Regulation which has both positive and negative repercussions for plastics recycling. While many adaptations will facilitate recycling within the EU, some measures on exports including the ban on all green-listed plastic waste entries exported to OECD and non-OECD countries outside the EU and EFTA will instead hamper European recycling.
In summary, EuRIC now calls on EU decisionmakers to consider the following five actions from the European plastics recycling industry:
- Harmonised EU end-of-waste criteria for plastics as soon as possible, allowing for international market access and competitive market conditions for high-quality recycled plastics and adapting applicability of export restrictions accordingly (Article 82).
- Proportionate export rules for processed high-quality recycled plastics, fully aligned with WTO law and the OECD legal framework, considering differential treatment between high-quality recycled plastics and unprocessed mixed plastic packaging waste, while carrying out a full impact assessment before setting any additional export restriction (Article 37 paragraph 2, Article 41 paragraph 2 and Article 42). In particular, mechanically treated plastic waste into flakes for end-markets for which there is no end-market within the EU shall not be subject to the ban on exports.
- Harmonised revocations grounds for pre-consented facilities, ensuring legal reliability and effectiveness of the pre-consented facility status and allowing a defragmentation of the EU single market (Article 14 paragraph 9 and 10).
- Keeping plastic waste entry EU 3011 and EU 48 for facilitating plastic waste shipments within the EU under same conditions for environmentally sound management (Annex III Part I paragraph 2 point g and Annex IV Part I paragraph 2 point f).
5. Mandatory recycled content targets for plastics beyond packaging, ensuring environmentally sound management of plastic waste and scaling up European plastic recycling facilities (Article 56 paragraph 2b). Recycled content targets for plastics in the ELV and WEEE legislation shall be a priority.
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Press Release | ENVI to dangerously damage European recycling with report on Waste Shipment Regulation
European recyclers warn of major incoherencies that remain after the ENVI report on the Waste Shipment Regulation was adopted on 1 December. While the report alleviates some of the administrative burdens that impede trade of recycled materials within the EU and sets mandatory recycled content targets for plastics, it completely turns a blind eye on plastic waste shipments within the Union and grounds of revocation for pre-consented facilities by local authorities.
Regarding exports, the restrictive approach announced by the Commission’s proposal has been strengthened by the report. Waste export restrictions go as far as to include an explicit ban on all plastic waste exports to OECD and non-OECD countries. For other resource streams, in particular metals and recovered paper, the report falls short in distinguishing them from problematic waste streams. Yet, EuRIC welcomes the distinction made between OECD and non-OECD countries.
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Press Release | A boost for recycling but non-recyclable packaging must be phased out sooner
The proposed Regulation on Packaging and Packaging Waste (PPWR) sets a robust framework to boost packaging recycling. However, European recyclers warn that the phasing out of non-recyclable packaging must be dramatically accelerated if the EU is to live up to its circular economy and climate ambitions.
Recyclers also regret the lack of ambition on recyclability targets arguing that design for recycling criteria – which enables packaging to be more easily recycled – must be fast-tracked for implementation before 2025, not 2030. Moreover, requirements to ensure packaging is effectively collected, sorted, and recycled at scale should be implemented by 2030, not 2035.
“COP27 experts warn of record high emissions in 2022. Recycling offers solutions to this crisis by lowering our demand for extracted raw materials, thereby reducing CO2 emissions, energy, and water consumption. Yet, we need a regulatory environment that enables recyclers to thrive and re-invest in Europe,” says Emmanuel Katrakis, Secretary General of the European Recycling Industries’ Confederation. “The proposed Regulation is a step in the right direction but does not go far enough in eliminating the use of non-recyclable packaging,” he added.
While recyclers enthusiastically support rules that mandate the use of recycled materials in new packaging, they note the need for more ambitious targets for beverage bottles and non-contact sensitive packaging, including compostable packaging. The additional demand for recycled materials spurred by these targets will enable recyclers to reinvest in innovation and the upscaled recycling facilities necessary for realising the circular economy and tackling climate change.
Finally, while recyclers support targets that promote packaging reuse, it is of paramount importance to ensure consistency between targets and provide the certainty needed by the value chain to invest and scale-up capacities. In addition, a distinction must be made between those materials that are highly recyclable but not necessarily best fit for reuse e.g., paper and cardboard, and those that are better suited for reuse.
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Joint letter | European recycling industry calls for unhampered trade for raw materials from recycling under the Waste Shipment Regulation (WSR)
The procedures for the export of recycled materials still classified as waste laid down in the Waste Shipment Regulation (WSR) are burdensome, costly, and time-consuming. European recyclers are therefore in favour of an ambitious revision of the WSR that effectively combats illegal shipments while levelling the playing field with extracted raw materials. In that respect, it is instrumental to simplify procedures for intra-EU waste shipments while ensuring free, fair, and sustainable access to international markets for raw materials for recycling (RMR) that are used directly in production processes. This is of particular importance for base metals, paper, or some plastics that have undergone a material recovery process and for which there is no sufficient demand in the EU. EuRIC and FEAD urge policymakers in this joint letter to consider the essential elements for the transition to a more circular economy in Europe.
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Press Release | European recyclers urge tougher scrutiny of EPR Schemes
European recyclers are urging European and national policymakers to exercise greater scrutiny before establishing new Extended Producer Responsibility (EPR) Schemes. Often portrayed as a silver bullet to improve waste management, EPR Schemes have significantly multiplied in recent years as the burden of the polluter-pays principle has shifted to producers. In its latest position paper, European recyclers warn that sufficient assessment of whether a waste stream has a positive or negative value is needed prior to establishing new schemes.
“EPR Schemes can be effective when they involve recyclers or their representatives in their governance bodies, thereby providing an expertise that manufacturers typically lack. They also have an instrumental role in bringing together manufacturers and recyclers through effective eco-modulation of fees that promote recyclability and recycled content,” says Emmanuel Katrakis, Secretary General of EuRIC, the European Recycling Industries’ Confederation. “Good examples exist with respect to end-of-life vehicles (ELVs) and industrial packaging, yet other notable Schemes pose a fundamental risk to recycling investments,” he added.
European recyclers argue that EPR Schemes should only be established where collection and treatment costs are adequately assessed and exceed the economic value of the waste stream. This includes deciding on appropriate governance, an organisational or operational role, and whether alternative policy instruments could be implemented. Recyclers, rather than EPR schemes, should retain ownership of the waste stream to maintain their ability to invest and scale up recycling, otherwise this will further erode the competitiveness of recycled over extracted raw materials. -
Press Release | European recyclers support Japan’s objection to proposed OECD rules on e-waste trade
In its latest position paper, European recyclers have united in support of an objection raised by Japan to new international rules that risk subjecting shipments of non-hazardous e-waste to burdensome administrative requirements.
Currently, around 53.6 million tonnes of e-waste are generated globally on an annual basis, and this is anticipated to increase to 110 million tonnes by 2050. E-waste is an intrinsically complex waste stream and proper collection and recycling play an instrumental role in preventing pollution from improper treatment. This maximises the environmental benefits in terms of resource, CO2, and energy savings. Efficient e-waste shipments are also vital to maintaining the pace that circular value chains recover e-waste.
E-waste recyclers in Europe are already well-equipped to tackle this societal challenge with state-of-the-art facilities that adhere to the most stringent environmental standards. As such, a functioning circular economy for e-waste that addresses environmental and human health concerns already exists. However, the new Basel Convention rules that may be incorporated into the OECD framework would impose additional burdensome requirements that risk derailing e-waste recycling.
“There is no need to reinvent the wheel,” says Olivier François, President of EuRIC, the European Recycling Industries’ Confederation. “Recyclers in Europe are already setting the benchmark internationally for their commitment to the highest environmental and human health standards in a market that already functions properly. Implementing the new Basel rules would risk inhibiting rather than facilitating e-waste recycling. Instead, regulatory intervention should focus on curtailing illegal shipments,” he added.
As such, European recyclers support Japan’s proposal to retain GC010 and GC020 in Appendix 3 Part II of the OECD Decision and not subject movements of non-hazardous e-waste within the OECD to the onerous administrative procedures obligated by prior informed consent.
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Position Paper | Proposed integration of Basel e-waste entries into the OECD Decision
Through its members, EuRIC represents the vast majority of e-waste recycling facilities in Europe and therefore has a strong interest in providing comments about the incorporation of the newly adopted Basel Convention entries into the OECD Decision which will enter into force on 1 January 2025 and concern all shipments of e-waste (new entries Y49 and A1181) as well as the objection raised by Japan on 15 August 2022.
The new Basel entries aim at directing e-waste that is moved transboundary to environmentally sound facilities with state-of-the-art technology. As noted in the Japan objection, OECD Members generally have a much greater capacity to ensure the proper recovery of e-wastes, including recycling infrastructure and legal frameworks for environmental protection and environmentally sound management of waste. Therefore, EuRIC strongly supports the objection raised by Japan and its proposal to retain GC010 and GC020 in Appendix 3 Part II and to not subject all transboundary movements of e-waste within the OECD to the prior informed consent (PIC) procedure.
Read more on EuRIC's views on the proposed integration of Basel e-waste entries into the OECD Decision by consulting our position below.