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:

  1. 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).
  1. 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.
  1. 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).
  1. 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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