European recycling at risk under the EU’s waste shipment proposals –

Waste shipments are vital to preserve the competitiveness of the European recycling industry. While strict rules must be put in place and more importantly enforced to combat illegal waste shipments which harm the environment and human health and the recycling industry, export restrictions applicable to recycled materials – otherwise known as raw materials from recycling (RMR) – will result in substantial EU job losses and further hamper the transition towards the circular economy.

The recycling industry is one of the fastest growing industries in Europe. It creates and sustains green local jobs across the EU. The average turnover of the European recycling industry amounts to 95 billion EUR annually.

Recycling obviously plays an essential role in Europe’s transition towards a circular and a climate neutral-economy. By turning waste into resources, recycling not only reduces Europe’s reliance on extracted raw materials from non-EU countries, it also significantly reduces CO2 emissions, energy and water consumption. For instance, European steel scrap recyclers alone saved, in 2018, 157 million tonnes of CO2 in 2018 an amount equivalent  to all automobiles circulating in France, Great Britain and Belgium.

Despite an ambitious Circular Economy Action Plan, a number of burdensome, costly and time-consuming barriers continue to impede recycling in the EU. The proposed revisions in the Waste Shipment Regulation (WSR) are a good example. Unfortunately, the Commission’s proposal only partially addresses to the current needs and, worse, creates more problems.

The EU recycling industry does applaud the introduction of electronic procedures and accelerating the fast-track shipments for materials recovery within the EU. On the other hand, however, the European Commission’s proposal falls short on waste exports outside the EU. By failing to distinguish between “problematic” waste streams such as mixed plastic, non-processed electronic waste (WEEE) and end-of-life vehicules, whose improper management results in environmental harm, and other raw materials from recycling which directly contribute to environmental protection the proposed revision creates an existential threat to European metals and paper recyclers in particular.

Firstly, substituting extracted raw materials with recycled materials saves resources, CO2 and energy regardless of where that substitution takes place. While the vast majority of waste recycled in the EU stays in the EU, exports of recycled materials to OECD and non-OECD countries directly contributes to the balance of supply and demand. This is particularly the case for steel, copper, aluminum or paper where supply exceeds demand in the EU. For instance, around 80% of high-quality steel scrap is used by the European steel industry while 20% is exported to countries whose steelmaking capacity largely relies on recycled materials. Regarding steel scrap, it is worth highlighting that over the past 10 years roughly 56% to 58% of European steelmakers rely on scrap. During that period, there has never been any steel scrap shortages in the EU. On the contrary, imports of ferrous scrap have decreased, and exports increased. In the case of paper, there is a surplus of 5 to 6 million tons exceeding European demand.

Secondly, contrary to false claims, export restrictions will damage the availability of raw material from recycling to European energy-intensive industries. Access to international markets is essential for balancing demand and supply in the absence of competitive end-markets for recycled materials which will negatively affect waste collection, recycling and investments to scale-up recycling capacities. As such, the proposed export restrictions will jeopardise reaching EU recycling targets.

Thirdly, a loss in competitiveness due to ill-targeted export restrictions will prioritise extracted raw materials over RMR. Indeed, extracted raw materials are not subject to similar trade restrictions under EU law. As a result, mining, whose negative environmental and climate impacts are not reflected in market prices, will become even more competitive than recycling.

Finally, a revision that hampers instead of boosts recycling in Europe will result in substantial job losses in an industry whose competitiveness largely depends on its ability to market recycled materials to cover the costs of proper waste management.

Up to 80% Europe’s leading metal and paper recycling companies have warned that the WSR proposals will negatively impact turnover. As such, the vast majority of them expect job losses, at a period where the industry is already under huge pressure due to sky-rocketing energy prices.

Worse, since the downstream market to whom the EU recycling industry sells, is composed of very few market players, the revised WSR will put recycling companies composed primarily of SMEs at the mercy of dominant multinational companies.

To preserve sound recycling markets that are a precondition to transitioning towards a resource and climate-efficient economy, the recycling industry would like to emphasise the absolute need, to ensure that:

  • Waste export restrictions focus solely on problematic waste streams, not on recycled materials;
  • A clear distinction is kept between OECD and non-OECD countries, to ensure that the EU abides by its international commitment towards the OECD. It is important that to ensure that changes affecting common interests in the fields of energy and raw and materials are negotiated in a multilateral framework, that the OECD provides;
  • The EU enforces existing end-of-waste criteria and develops new criteria where absent to clearly distinguish between waste & raw materials from recycling;
  • Set harmonised end-of-waste criteria to clearly distinguish raw materials from recycling from waste;
  • Mandatory recycled content targets are set to boost circular value chains in Europe and drive the substitution of extracted raw materials with recycled materials beyond plastics.


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