Opinion on the Commission’s Proposal for a Circular Economy Strategy and Reviewed Waste Legislation

CEEP Opinion on the Commission’s Proposal for a Circular Economy Strategy and Reviewed Waste Legislation, adopted by CEEP General Assembly on 16 May 2016.

Executive summary

• CEEP welcomes the European Commission’s Circular Economy Strategy and the legislative proposals on waste for their holistic approach, taking into account the whole value chain. They are an important step towards a more circular economy in which resource efficiency becomes the key driver for both economic growth and environmental protection.
• CEEP agrees that waste prevention has rightly been placed at the top of the waste hierarchy. This includes in particular improved product design, influencing the whole product lifecycle and durability of a product and thus optimising its future reuse and recycling. EU legislation needs to be further adapted in order to support this ambition.
• CEEP supports the Commission’s proposal to introduce clear definitions into waste legislation and welcomes that the definition of municipal waste is closely aligned with the one given by the European Waste Catalogue and the OECD. However, CEEP pleads that the definitions of both municipal waste and bio-waste should refer solely to their nature, property and composition, and not their quantity.
• CEEP underlines that the proposed recycling targets for municipal waste are very ambitious. Recycling measures should be further boosted in the European Union. This should be done as long as recovery of secondary raw material is less expensive and resource intensive than primary raw material extraction. It should also be kept in mind that primary and secondary raw materials need to be treated equally in a way that same environmental requirements should apply to both.
• CEEP welcomes the introduction of minimum requirements for Extended Producer Responsibility (EPR) schemes while leaving it in the remit of the Member States to decide on the use of this instrument. Nevertheless, more clarification is needed in order to avoid misinterpretations, in particular regarding cost recovery and the relation between organisations in charge of the implementation of EPR schemes and public waste management operators.
• CEEP asks for a quick landfill ban for biodegradable waste as well as for waste that can be recycled or thermally recovered. Such a ban needs to be introduced in all Member States as this would be the most effective way to support waste prevention, reuse, recycling and other efficient ways of recovery.