EuRIC Position on the Revision of the Waste Shipment Regulation

One of the founding assumptions of the circular economy is that wastes are resources. Circular material flows require waste and secondary raw materials to circulate at the pace of businesses to be recycled and used to manufacture new semi-finished and finished products. 

The Waste Shipment Regulation (EC) No 1013/2006 (WSR) causes substantial administrative burdens due to overly complex and outdated procedures which make it sometimes impossible for recycling companies to ship secondary raw materials from one EU-Member State to another. Incidentally, it fosters linear material flows as it is, from an administrative procedure, much easier to import raw materials mined or harvested outside Europe with much lower standards than to ship waste for material recovery within the EU.

In line with the goals of the European Green Deal to build an internal market for secondary raw materials, it is much needed to alleviate obstacles to circular value chains in Europe and beyond as well as to boost the market for secondary raw materials. EuRIC therefore calls for a well-functioning market for the shipment of secondary raw materials and proposes in order to do so to improve and simplify the notification procedure as laid down in Article 4 et seq. as well as the Annex VII procedure as laid down in Article 18 et seq. Harmonized electronic waste shipment procedures throughout the EU should become the norm and gradually replace paper based procedures. In doing so, a transition period might be required to ensure that Member States systems are rendered fully interoperable and that operators have the necessary time to adapt.

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