Fead especially welcomes the request to the Commission to present a comprehensive review of the Ecodesign Directive. The federation believes that the Ecodesign Directive should go beyond energy efficiency and improve measures for material resource efficiency. The success of the development of eco-design will also depend on the capacity to foster ongoing efforts and innovation. Material resource efficiency can be improved through the establishment of durability, repairability and recyclability requirements, for selected products (such as electronics).
The federation also agress with stressing the importance of the use of economic instruments to incentivise the uptake of secondary raw materials (SRMs). Fead points out that the draft report only mentions green public procurement and recycled content, however, the federation believes there are other efficient instruments that should be used. Measures to incentivise the use of SRMs should include e.g.: financial rewards for energy savings and CO2 reduction from recycling, encouraging Members States to introduce a green tax shift in favour of activities supporting the transition to circular economy, internalisation of external costs of primary raw materials, fiscal measures, such as lower or zero rate of VAT on SRMs and on products that incorporate recycled materials.
Finally, Fead agress on the re-introduction of the definition on prepare for re-use currently in force in the WFD. Fead sees the need to maintain a clear distinction between “prepare for re-use” and “re-use”, the latter being a waste prevention measure. The WFD only regulates waste, not products. Extending the definition of “preparation for re-use” to products, which have never been waste, would cause major problems for reuse organisations and lead to an increase of the overall recycling rate of municipal waste which is unrelated to better performance in recycling. For the same reasons Fead welcomes Amendment 126, which closes the door for re-use to be included in the calculation of the targets.
There are some elements however which Fead believes will need further development during the negotiations on the package. In particular, the deletion of the criterion on quantity in the definition of municipal. The scope of the term “municipal waste” should not be broadened to include commercial and industrial waste not similar in nature, composition and quantity to household waste (all three criteria proposed by the Commission). These criteria are key to define “similar” household waste. If not, the set target on municipal solid waste risks to unduly include commercial and industrial waste, the collection of which should not be financed and cross subsidised by public funds. Hence, the criterion on “quantity” is of key importance and shall be kept. At the same time rapporteur, MEP Bonafè, recognises the importance of the criterion on “quantity” in her justification for proposing a definition on commercial and industrial waste welcomed by Fead. The justification for Amendment 42 reads as follows: “Municipal waste needs to be distinguished from waste deriving from other economic activities which cannot be considered to be similar due to its nature, composition and quantity”. Therefore, Fead strongly supports the idea to use the quantity criterion to clearly draw the line between municipal waste on one hand, and commercial and industrial waste on the other. This will become even more important in view of reaching the recycling target by 2025 and 2030 on these and other waste streams for the EC to examine by 31 December 2018 as called for by the Rapporteur.
Fead supports a harmonisation of the calculation method as this will improve the reliability of statistics. However, the private waste and resource management industry regrets that the possibility to measure the output of a sorting plant is deleted. Fead members wish to stress that both the “input to the final recycling process” and the “output of a sorting plant” should be equal alternatives as the method chosen will depend on the waste flows. E.g. separately collected kitchen waste or paper waste can enter “final recycling processes” without prior sorting whereas measuring at the sorting plant (“output of sorting”) works better where two or more dry recyclable materials are collected together and sent for sorting before reprocessing.
Measuring after sorting is also more practicable for waste which is shipped for recycling to another Member State or outside of the EU. The further down the recycling chain, the more difficult it becomes to trace back the origin of the waste and hence assign the recycling rate to the Member State in which the waste was collected for recycling. In some Member States waste codes change after a treatment process, turning municipal waste into commercial or industrial waste, even if the origin was municipal waste. Furthermore, the final reprocessor usually receives input from several sources (municipal as well as commercial and industrial) and lacks knowledge about the origin of the waste. Fead members therefore deem that measurement at the “output of the sorting plant” should remain possible as it will be the most reliable method in terms of statistics which serve as a basis for policy and business decisions.
Finally, Fead reminds that open markets and fair competition are of key importance to facilitate the move from a linear to a more circular economy. To do so, market based conditions and competitive tenders must be introduced in the whole value chain. A level playing field between private and public operators is crucial to maximise competitiveness within the sector and would help unlock more green growth and jobs in Europe.