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No place for 'pull mechanisms' in new leaked circular economy briefing

The European Commission continues to maintain that demand side measures to boost the market for secondary raw materials will play no part in its revised circular economy (CE) package, according to a leaked briefing.

MRW exclusive

MRW has seen a new version of an advanced internal document on an action plan to underpin the CE proposals due to be published on 2 December.

On 15 October, MRW reported exclusively on a preliminary document understood to have been written towards the end of this summer’s public consultation.

The latest version says the role of the private sector is essential in creating demand for secondary materials, helping to shape supply chains and market mechanisms, and it refers to existing voluntary agreements in some sectors.

Public authorities’ procurement policies are also mentioned as a driver but, as suggested in the initial document, it is emphatic that “prescriptive EU action would not be effective or proportionate”.

This appears to rule out, for example, tax incentives for the use of secondary raw materials or mandatory minimum levels of recyclates in products.

However, the action plan does propose cutting cross-border red tape through electronic data exchange and improving available information on secondary materials.

It also says the Commission will develop quality standards for secondary raw materials where needed, in particular for plastics.

There is concern from the industry about who would buy secondary materials at prices that would cover all the processing costs, especially where they are not competitive with primary materials in a weak market.

The Enviromental Services Association (ESA) has repeated its reaction to the previous document, that it gives “insufficient emphasis to the demand side measures needed to create sustainable markets for secondary raw materials”.

Roy Hathaway

ESA Europe policy adviser, Roy Hathaway (pictured) told MRW: “The Commission appears to believe that if you keep hammering on about quality there will be buyers.”

There is a specific focus on plastics, with a strategy on the recyclability, biodegradability and the presence of hazardous substances.

Percentage targets for the recycling of plastic packaging, as yet unspecified, are also included in the document.

The same is suggested for wood packaging, including the introduction of separate collection of the material.

As mentioned in the previous leaked briefing, the Commission is proposing to differentiate fees paid by producers in extended producer responsibility (EPR) schemes according to the “real end-of-life costs and recyclability of their products”.

The revised proposal also include rewards for promoting reuse activities at national level and improved market access for reuse centres.

The CE package will adopt measures to improve the identification of illegal waste shipments and promote voluntary certification of treatment facilities for key waste streams.

Country-specific recycling targets and landfill action, all suggested in the previous leaked briefing, are still to be decided. As with the previous document, references to landfill are all within parentheses, suggesting more concrete policy in this area remains to be framed.

The briefing also says the Commission will adopt an initiative on energy from waste in the framework of the Energy Union Directive.

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