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.

Improving the design of products is a pre-condition to transition towards a circular economy. As it has already been highlighted in the report released by the European Recycling Industries’ Confederation (EuRIC) named “Top 5 Priorities of the Recycling Industry for the Period 2019 -2024”, 80% of products’ environmental impact are determined at a design stage. Although the above-mentioned fact is also stated in the new Circular Economy Action Plan (CEAP), the vast majority of products placed on the EU market – and not only – are still designed without any consideration for their end-of-life stage. Design for circularity is of an outmost importance to move towards a more circular economy and needs to be extended to all products’ categories, including photovoltaic modules, inverters and systems. Improving the design of products is a pre-condition to transition towards a circular economy.

EuRIC thus fully supports the necessary ‘Environmental impact of photovoltaic modules, inverters and systems’ legislative initiative to keep the already exploited resources - used for the manufacturing of photovoltaics modules, inverters and systems - in the market for as long as possible while at the same time significantly reducing the negative environmental impact that the in-question products are generating when are not designed to support and promote sustainability.

Europe’s metal recycling industry is one of the fastest growing industries, providing local, non-outsourceable jobs.  Composed of SMEs and large players, it offers a unique infrastructure of facilities and processing plants spread all over Europe. Metal recyclers supply steel mills, smelters and foundries located in and outside Europe with commodity-grade metal scrap from recycling, thus playing an essential role in the circularity and climate-neutrality of metals.

Given their intrinsic properties, metals are indefinitely recyclable, making them circular by nature. In addition, the recycling of end-of-life products containing metals is climate-efficient. When compared with raw materials extraction often mined in non-EU countries subject to lower human rights, health and environmental standards, metal recycling saves massive amounts of CO₂. Steel, aluminum and copper recycling save respectively 58%, 92% and 65% of CO₂ emissions, to name only a few. However, prices still fail to reward these environmental benefits, thus EuRIC calls for incentives to correct this market failure and direct investments in circular value chains. More importantly, metals are valuable making them unlikely to be littered or removed when reaching end-of-life stage but collected and recovered to close new material cycles. Thus, unwanted metal waste is not a problematic stream.

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WEEE Forum, EuRIC, EUCOBAT, EERA, MWE and the WEEELABEX Organisation join forces to counter the occurrence of fires caused by lithium batteries and e-waste containing lithium batteries. A new report compiles good practices addressed to all actors in the value chain and covering all phases of products’ lifecycle.
More and more electrical and electronic products in everyday life contain batteries, making life more convenient and pleasant. However, those same batteries, when damaged, also increasingly cause fires.

In the past few months, organisations representing the industry that manages the collection and treatment of spent batteries and electronic waste (WEEE) along with manufacturers of home appliances and consumer electronics, gathered to exchange views about this issue of growing concern in order to design measures to counter the frequent occurrence of fires. A survey among recyclers resulted in a better understanding of the issue of fires in the WEEE management chain. The report , “Recommendations for tackling fires caused by lithium batteries in WEEE”, has been prepared by the WEEE Forum and EuRIC with the active contribution of experts from various organisations including the co-signatories EERA, EUCOBAT, Municipal Waste Europe and the WEEELABEX Organisation. The report presents a set of recommendations and good practices aimed at countering the occurrence of fire incidents caused by lithium batteries and WEEE containing lithium batteries.

“The report concludes that there is not a magic formula that will eradicate the risk of fires caused by WEEE containing batteries”, says the WEEE Forum. “It is imperative that actions are taken urgently in all steps of the lifecycles of EEE and lithium batteries and by all actors in the value chain: from design to disposal of WEEE and batteries including the consideration of transport and treatment. For this, further work to assess the extent of the issue and potential solutions is required’’.

A thermal event may become a severe incident if is not rapidly detected and extinguished. Training, prevention, and detection measures are therefore essential for identifying and tackling risky situations. The report comprises recommendations and good practices addressed to the main participants in the steps of the EEE and WEEE value chain and includes recommendations to producer responsibility organisations of EEE and batteries, to local authorities, and policy makers.

“The European Green Deal and the new Circular Economy Action Plan identify ‘electronics’ among key product value chains where recycling plays a major role in achieving sustainability goals. Battery fires are a genuine challenge for the recycling industry and the entire value chain. Properly addressing the risk of fires caused by WEEE containing lithium batteries through a multi-stakeholder approach is essential to support electronics’ recyclers which play an essential role in the achievement of the EU’s overarching sustainability goals”, says EuRIC.

Reaching climate neutrality by 2050 will require drastic changes throughout all value chains, in particular for energy-intensive industries such as metal production. Thanks to their intrinsic properties and market value, discarded metals have been recycled for decades and used to produce new ferrous and non-ferrous metals again and again.

Metal recycling is a must to achieve the climate and circular economy targets set by the European Green Deal and the new Circular Economy Action Plan. Metals are essential in both products and systems which are essential to a low-carbon economy and everyday products. Compared to primary production, steel, aluminium or copper recycling save respectively 58%, 92% and 65% of CO² emissions and spare primary raw materials often extracted outside Europe where much lower standards apply.

Despite enormous environmental benefits, substantial bottlenecks keep hampering metal recycling in Europe.

• The first one has to do with the fact that Europe’s industry remains mostly linear with only 12% of the materials it uses coming from recycling. As a result, in Europe, the supply of metal scrap from recycling meeting industry specifications often exceeds the demand and remain under-utilised in metal production.
• The second one relates to the fact that commodity prices still fail to internalise the massive environmental benefits of metal recycling. There is in EU legislation no incentive that rewards metal recycling lower-carbon and energy footprint when compared with primary raw materials (often extracted outside Europe).
• The third one is rooted in European waste legislation which hinders more circularity. Metal scrap is a valuable commodity, with a positive environmental footprint, which should not be classified as waste but as secondary raw materials. In addition, a number of procedures pertaining to cross-border shipments or to permitting remain far too burdensome to incentivize circular metal value chains.

For Cinzia VEZZOSI, President of EuRIC, “Time has come to lay down a more ambitious strategy to boost metal recycling in Europe and support the entire metal value chain, which is a backbone of any modern economy”.

She stressed in particular the absolute need to set up framework conditions and incentives that steers metal recycling and metal production from secondary raw materials by rewarding their environmental benefits. “This should be one of the priorities of the EU Recovery Plan”.  Taking the example of steel, “it is key to support value chains currently striving to migrate from current blast furnaces which use primary iron ore and coal, to electric arc furnaces which use recycled steel and can use power from renewable sources. Low-carbon impact steel and metals in general are not only vital to achieving climate neutrality, it is also instrumental to compete better in a rapidly changing market”, Vezzosi added.

Of equal importance is the need to simplify legislation applicable to circular value chains. “To create a well-functioning EU market for secondary raw materials, metal scrap meeting industry specifications shall no longer be classified as waste. We need to align legislation which hampers the transition towards a more circular economy with overarching EU policy objectives embedded in the Green Deal otherwise circular frontrunners won’t be able to deliver”, she stressed.

Last but not least, guaranteeing free, fair and sustainable trade is more important than ever. We need to refrain from setting any trade restrictions negatively impacting metal scrap processed to industry specifications which operates on an inherently global market. Forthcoming measures shall focus on better pricing carbon-intense imports to level the playing with low-carbon products made of recycled materials.