The Regulation controls both imports and exports, of both hazardous and non-hazardous wastes, within the EU and to third countries outside the EU. The existing Regulation had set the rules to ensure potential adverse effects on the environment and public health caused by shipments of waste are avoided. With this proposal, the Commission intends to strengthen those rules.
BIR fully supports regulations that aim at the protection of both human health and the environment, and also supports that that recyclables can be moved to facilities that are environmentally soundly managed, and that raw materials from recycling can be transported to manufacturing industries in the global circular economy.
However, the proposal significantly diverges from free and fair trade in an open intention to reduce the cost of materials within the EU, allowing those in the EU “to use more waste as feedstock, which they should be able to purchase at a lower price”. BIR stresses that these trade restrictions, artificially lowering the costs of materials in the EU for the EU manufacturing industry, will affect the capacity of the European recycling industry to invest in efficient and innovative recycling capacities and processes. Also, by cutting access to outside markets, they will result in excess volumes which will be lost to the global circular economy. Such changes will finally have a counterproductive effect on the implementation of a truly global circular economy.
BIR, together with its European Member associations, is willing to contribute to the long co-decision process that will now start, involving the European Parliament and the Council of Ministers throughout the next year.
With regards to the Commission’s statement “A robust and integrated market for secondary raw materials is a cornerstone of a well-functioning circular economy.”, BIR Trade & Environment Director Ross Bartley comments: “The regulatory burdens placed on EU secondary raw material suppliers by this proposal far outweigh those on competing primary raw materials suppliers and their imports into the EU.”