To enable the circular economy in a competitive and innovation driven way, with the minimum environmental impact, waste managers need an economy of scale in which end-of-life products can find its way to the most adequate and specialised facilities in order to be recycled into valuable secondary raw materials that will re-enter the product’s value chain.
Unnecessarily heavy, costly, and lengthy procedures are trade impediments to circular business models, which should be based on open and safe markets.
Following a survey among the members of both associations, the results show clear deficiencies and big disparities, for example, in the implementation of the Prior Informed Consent (PIC) procedure. It is therefore critical to update and improve the procedure to make it simple, online, and transparent, while strengthening the pre-consent status for facilities and revising the financial guarantees by including a risk-based approach.
FEAD and EERA strongly advocate for such improvements that will facilitate the trade of recyclables in an environmentally sound and economically efficient manner, and they hope that the practical examples provided will serve the legislators and competent authorities to address the issue and implement the needed reforms in the system.
Kurt Kyck, EERA President, said: “The pre-consented status for facilities must become a reality recognised by all competent authorities in OECD countries. For this to happen, it should become a mandatory obligation to implement, and not a mere possibility. It is worrying to see that 30 years after its regulation, members reported there being little or no difference in the administrative and financial burden between a consignment made to a pre-consented facility or not”.
Peter Kurth, FEAD President, said: “Notification procedures are currently long and burdensome, which needs to change if we want to make the circular economy a reality. In this sense, the unification and harmonisation of administrative costs is also important. These are currently prohibitively high and not proportional to the risk, costs or work involved, and significantly increase the overall financial burden of legitimate global e-waste operators. What we are asking for is harmonised, transparent, risk-based requirements that result in reasonable and justifiable administration costs”.