Opinion on the Circular Economy Action Plan

Executive Summary

• Instead of establishing new regulatory measures in waste legislation, the focus should be on waste prevention and to support Member States risking to fail recycling and waste prevention obligations;

• In order to enhance a proper waste prevention at source, producers need to implement sustainability principles in product design therefore we highly support the Commissions’ sustainable product initiative;

• Supply and demand for secondary raw materials are essential for the development of Circular Economy and should be therefore strengthened. For this aim, both legislative and economic measures have to be applied to support the development of a solid market for the secondary raw materials. For this reason, an effective system of development for End of Waste Criteria at EU-level should be considered, along with new requirements for recycled content for proper product categories;
• More support for recycling methods in building infrastructures and adequate binding targets; i.e. foster large-scale European experimentation in low-carbon construction and refurbishment systems that comply with the principles of recycling and draw up the new applicable rules;
• Better use and linkage with the EU Digital Strategy, which can provide multiple innovative solutions and pathways for the transition to a Circular Economy for the waste, waste-water and energy sector;
• Waste to energy must be part of a sustainable circular economy, as it is needed to implement the landfill ban, as a sink for hazardous substances, as a renewable energy resource and to recover valuable secondary raw materials;
• Keep improving the enforcement of the Waste Hierarchy in every Member State in order to reach the GHG emission reduction targets for 2030 and 2050. For the waste sector, the aim must be to end landfilling of untreated municipal waste already by 2030;
• SGI Europe calls on to the European Commission to build the necessary close relationship with SGI Europe and its EU Social Partners for identifying sustainable options and conditions to make the CEAP a success in Europe for the environment, the economy and workers.