Waste Framework Directive: Industry bodies express “serious concern” over recycling definitions

10 Jan 2024 --- A cross-body of industry associations in the waste management and recycling sectors is calling on the European Commission (EC) not to impose extensions to the Waste Framework Directive (WFD) that would classify waste-to-fuel (WtF) practices as a form of recycling. 

In an open letter, the Confederation of European Waste-to-Energy Plants (CEWEP), EuRIC — representing the European recycling industry, the European Waste Management Association (FEAD) and Municipal Waste Europe (MWE) signed their “serious concern” over amendments to the WFD. 

Especially problematic are amendments to articles that would create the possibility of changing the definition of recycling to include the production of fuel products from materials, including waste, say the organizations. 

“The ambiguity of such a proposal threatens all ongoing investments in recycling capacities and technologies.” 

The waste hierarchy outlined in the WFD categorizes WtF solutions as energy recovery, which is ranked below material recovery (recycling) and above disposal (landfill or incineration without energy recovery). 

WtF should not be defined as a form of recycling, say the organizations.“Broadening the definition of recycling to include waste converted into fuels risks watering down the waste hierarchy and could have a high environmental impact if certain wastes cease to be considered as waste and are seen as fuel, a product,” reads the letter. 

“Aside from undermining material recycling, this would mean that these wastes would no longer be subject to the strict requirements of EU waste legislation, including the Waste Shipment Regulation.” 

Mixed waste sorting systems
The introduction of mandatory “mixed waste sorting systems” is another concern for the groups since such measures must first be subject to an impact assessment. 

While maximizing recycling is strongly advocated by the associations, they estimate that such a measure would correspond to 60 million tons of additional waste sorting infrastructure capacity across the EU. 

“The costs and benefits of introducing such mixed waste sorting systems across the EU must be assessed for all waste flows, looking at the impact on the whole value chain.” 

The signatories highlight three central points for the EC to consider in its reforms: 

• Textile waste has particular requirements, including the need for separate collection to prevent cross-contamination from other waste flows and proper management in dry spaces to avoid damage from humidity. This means that the quality of textile waste sorted out from residual municipal waste cannot be suitable for reuse and/or recycling compared to that collected separately.
• A cost/benefit analysis and environmental impact assessment of this proposal must be based on actual figures rather than theoretical data and assumptions. This analysis requires full transparency throughout the value chain, from the input to the sorting plant to the final recycled product.
• The efficiency of this measure will also depend on local conditions (available space, most efficient location, objectives, i.e., targeted waste streams as a function of the local waste management system). Local authorities and waste management companies must be considered to design systems that deliver the best outcomes.

“For these reasons, the undersigning associations strongly believe that the scope of this revision must be tailored to the available time before the end of the mandate and the scope of the EC’s preparatory work, including the impact assessment and public consultations.”

Edited by Louis Gore-Langton