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In search of a fair deal for the industry

As the replacement for the circular economy package negotiates its way through the EU’s political forum, the British Metals Recycling Association has set out what it believes should be five core elements of the new Directive.

1. Turning waste legislation into a resource-oriented regulatory framework

The circular economy package should aim to move everyone’s perception of waste to that of a resource. Waste legislation should continue to drive better resource management and prioritise between treatment types by establishing a clear waste hierarchy.

The EU ‘waste’ legislation should be relabelled as ‘resource’ legislation. The waste hierarchy should prioritise resource treatment and measures to improve its implementation, such as banning the landfill of recyclables and phasing out incineration of unsorted wastes.

Despite the Landfill Directive, tonnes of materials with valuable fractions are lost that could have been recycled. Some of these materials retain their value long-term and the restrictions on landfill mining should be eased.

2. Setting recycling targets to drive investments towards 2030

EU targets have contributed to an increase in recycling in many member states. The introduction of ambitious targets will build on this success.

Common, long-term EU-wide recycling targets contribute to legal certainty which is a prerequisite to investment. Waste streams must be clearly defined to allow for meaningful comparison of recycling rates among member states. There is an overriding need to keep the existing Waste Framework Directive definitions, and not to define waste dependent on the collectors.

Progress must also be measured via a common, simple calculation method for companies and enforceable by competent authorities.

3. ‘Pull’ mechanisms to drive the demand for recycled materials and to correct market failures

Virgin and recycled materials compete with each other but have different cost structures and environmental effects. Price-setting is mainly driven by primary fossil fuel and virgin resource use and net environmental benefits are not factored in. This needs to change as consideration for the environmental impact of every manufacturing process is a core element of sustainability.

4. Making more with less: reducing administrative burdens

Administrative burdens have increased over time and represent a major bottle­neck for recycling. A combination of the continuous tightening of waste legisla­tion with poor enforcement has seen the growth of illegal activities.

Making legislation simpler for recycling activities is a prerequisite for a circular economy. Action to improve enforcement must be taken by domestic governments and the European Commission.

The control systems stemming from the Waste Shipment Regulations are not functioning properly. Replacing the current paper-based notification procedures with electronic procedures would align administrative procedures with the pace of business and enhance traceability, which is vital in the tracking of illegal activities.

Improving the interplay between EU waste and chemical laws is vital. Removing hazardous substances and components from end-of-life products is standard practice for recyclers. To improve the recyclability of material, a reduction in the use of hazardous substances at the design stage is needed.

It also necessary to implement a risk-based approach to recycling, especially when only trace elements of a hazardous substance are present. This means optimising requirements of different legislation to avoid disproportionate obligations which hamper recycling.

5. Undistorted competition, crucial to a market-driven circular economy

Achieving undistorted competition within the waste management and recy­cling markets will dictate the success or failure of a circular economy. Recycled materials are valuable resources, and measures are needed to correct market failures and create conditions to move towards a circular economy.

Operating requirements should improve transparency and fair competition to avoid the creation of monopolies, as well as secure non-discriminatory access to recyclables and fair revenues for recyclers.

A circular economy cannot stop at EU borders. Access to the world’s markets is crucial to avoid price distortions and ensure that Europe’s recycling industry remains competitive.

Ian Hetherington is the director general of the British Metals Recycling Association (BMRA)

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