The waste and resource management sector plays a dual role: it is both a public service ensuring environmental protection and health, and a strategic enabler of a competitive circular economy, recovering materials and energy, while reducing Europe’s dependency on virgin resources.
FEAD urges the European Commission to adopt a bold approach: one that goes beyond critical raw materials and lays the foundations for a truly circular European economy. One that enhances strategic autonomy, supports domestic industrial ecosystems, and delivers local jobs.
Our 10 recommendations aim to address persistent market failures, boost the competitiveness of recycled materials, ensure fair and transparent markets, and promote effective implementation and enforcement across the EU.
FEAD’s 10 Policy Recommendations:
- Boost demand for recycled materials through binding recycled content targets, a 25% CMUR by 2030, economic incentives (VAT relieves, tax credits), and mandatory green public procurement.
- Create a competitive market for recyclates via targeted funding, tax reforms, and balanced State aid rules.
- Adopt EU-wide End-of-Waste criteria to enable a real Single Market for secondary raw materials.
- Ensure fair trade and competition by applying mirror clauses to imports, enhancing traceability, and avoiding trade distortions.
- Simplify permitting and waste shipments with harmonised, digitised, and accelerated processes across the EU.
- Reform EPR schemes to address market failures, drive eco-design, and uphold fair competition.
- Support Waste-to-Energy (WtE) for non-recyclable waste and invest in modernising infrastructure.
- Manage substances of concern through upstream restrictions, decontamination, and polluter-pays-based financing.
- Strengthen enforcement to ensure level-playing fields and consistent rule application across Member States.
- Reduce fire risks from lithium batteries via a Battery Fire Fund, Deposit and Return Systems, and EU risk assessments.
FEAD has already started engaging with EU institutions to advance these goals, including a meeting with the Commissioner for Environment, Water Resilience and a Competitive Circular Economy, Jessika Roswall and her cabinet on 25 April. During the meeting, FEAD presented its proposals with the support of several Board members, representing some of Europe’s leading waste management and recycling companies. A well-designed Circular Economy Act must be a pillar of the Clean Industrial Deal and respond directly to the EU’s industrial and environmental needs, as highlighted in the Commission’s Competitiveness Compass.
