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29 Mar.2017

Joint letter on alignment of Renewable Energy Directive with the Circular Economy Policies

TO: Members of the European Parliament ITRE Committee

Subject: Alignment of the revision of the Renewable Energy Directive with the Circular Economy Policies

Dear Members of the ITRE Committee,
Ahead of the report of the ITRE committee on the revision of the EU Renewable Energy Directive (RED II), the undersigned organisations, representing plastic and paper recyclers and zero waste associations around Europe, would like to bring to your attention our concerns as regards to inconsistency of the Commission’s proposal in RED II with the Circular Economy policies and the EU’s climate policy agenda.

This is due to the consideration of the biomass fraction of mixed municipal solid waste as a source of renewable energy when it is actually burning thanks to other materials (e.g. plastics and paper). Member States are consequently allowed to support various forms of energy generation from waste, to meet targets set under the RED II. These schemes which support waste-to-energy generation from mixed municipal waste, run counter to the EU’s transition to a low-carbon and circular economy, furthermore this would work to:

1. Undermine the Waste Hierarchy and the Circular Economy policies
Financial support for waste-to-energy from mixed municipal waste subverts one of the cornerstones of the EU waste policy – the waste hierarchy -, which establishes an order of priority in waste prevention and management i.e. prevention, preparation for re-use, recycling, other recovery (energy recovery), and disposal1. Waste is therefore meant to be firstly prevented, then prepared for reuse and, finally, recycled. Conversely, the RED II classifies it as a source of ‘renewable energy’ and allows renewable energy support schemes that conflict with the waste hierarchy by encouraging waste-to-energy processes, which is the second least desirable option of the waste hierarchy.

The effect so far has been a clear distortion of the market whereby investment in waste infrastructure and operation costs are organised on the basis of subsidies for the extraction of energy from waste instead of sound environmental and economic performance of the best waste management option. As a result, several European countries e.g. Denmark have overinvested in energy-from-waste plants whilst underinvesting in recycling facilities.

2. Undermine the Communication on Waste-to-Energy in the Circular Economy
The RED II also contradicts the Commission’s recent Communication on the Role of Waste-to-Energy in the Circular Economy which states that public financing of waste management, whether national or at EU level, should be consistent with the waste hierarchy and Member States should phase-out public support for the recovery of energy from mixed waste in line with the separate collection obligations and more ambitious EU recycling targets proposed in the legislative proposal on Circular Economy2.
1 http://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf
2 http://ec.europa.eu/environment/waste/waste-to-energy.pdf

3. Undermine the EU’s Climate Policy Agenda
The Commission’s proposal also undermines the EU’s climate agenda by supporting energy generation from mixed municipal waste, which is never solely composed of biogenic carbon. Much of the calorific value from waste-to-energy processes from mixed waste (incineration, pyrolosis or gasification) comes from the treatment of fossil carbon based materials such as plastics. For example, a typical waste incineration facility has a carbon intensity of approximately 600 kg CO2 eq. per MWh of electricity. This compares with a figure of 380 kg CO2 per MWh of electricity at an efficient natural gas power station using Combined Cycle Gas Turbine technology3.
Moreover, the monitoring of the amount of the proportion of organic waste compared to the amount of fossil-based waste in municipal mixed waste is both logistically and technologically difficult. It’s often assumed that the proportion is 50% - even if industrial and commercial waste is frequently included in the mix of waste entering a waste-to-energy facility. Given the heterogeneity of waste and the great differences from plant to plant, this percentage is neither constant nor reliable, which supports the evidence that much of the so-called renewable energy from waste-to-energy comes in fact from incinerating fossil carbon based materials.

The undersigned organisations therefore urge the members of the ITRE Committee to align the Commission’s proposal for a revised Renewable Energy Directive with the circular economy policies by explicitly excluding primes of subsidies for waste-to-energy generation from the mixed municipal solid waste.

Kinds regards,
On behalf of signatories
Joan Marc Simon
ZWE Executive Director
Contacts:
Janek Vahk, Development and Policy Coordinator, Zero Waste Europe: janek@zerowasteeurope.eu
Ulrich Leberle, Raw Materials Director, The Confederation of European Paper Industries: u.leberle@cepi.org
Antonino Furfari, Managing Director, Plastics Recyclers Europe: antonino.furfari@eupr.org
3 https://www.zerowasteeurope.eu/downloads/the-potential-contribution-of-waste-management-to-a-low-carbon-economy/

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14 Mar.2017 ,

Made to measure ‘real’ recycling rates will target investment where it matters most

The European Parliament has today opted to follow the ambitious lead set by Environment committee’s vote on the Circular Economy package in January this year.


The most important outcome from today’s vote is that MEPs moved in favour of one single calculation method that enshrines real and comparable recycling rates both in and for Europe.


“Today, the European Parliament has fully grasped the opportunity to make the Circular Economy work for Europe by enabling industry and local authorities to better target where investment needs to take place” says CEPI Director General Sylvain Lhôte


CEPI recognises that the new recycling targets are ambitious while providing new opportunities in terms of improving quality.


“For an industry where over half of our feedstock comes from paper for recycling, the Parliament’s approach means greater use of raw materials whilst putting the emphasis on quality” says CEPI Raw Materials Director Ulrich Leberle


The vote to encourage the use of bio-based packaging also demonstrates the importance of a Circular Economy that builds upon Europe’s wealth of renewable resources while accelerating the transition towards a low-carbon economy.


Finally the continued assertion of the separate collection of paper is viewed by the European paper and board industry as a means to bridge ambitious targets with higher quality recycling.


CEPI together with other partners in the European paper value chain will shortly publish its updated European Declaration on Paper Recycling where it addresses its commitment to the new targets.


The Circular Economy is one of the core elements necessary to achieving industry transformation in Europe as outlined in our ‘Investment Roadmap’ towards a low-carbon bioeconomy. Check out our alignment matrix for the full picture.


For more information, please contact Ulrich Leberle at u.leberle@cepi.org or by phone at (+32) 2 627 49 23
For press related enquiries, please contact Ben Kennard at b.kennard@cepi.org or by phone at (+32) 487 39 21 82
 

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09 Mar.2017 ,

Waste Framework Directive: European material industries renew call for measurement of real recycling rates

Europe‘s metals, steel and paper industries renew their call for a harmonised method to measure Member State recycling rates at input into the 'final recycling process'. The full document can be consulted via the link below.
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24 Jan.2017 ,

ENVI committee vote: one step closer towards a truly circular economy in and for Europe

The Confederation of European Paper Industries (CEPI) welcomes today’s vote in Environment Committee (ENVI) strengthening the foundation of a truly circular economy in Europe.
MEPs are now one step closer to building a truly circular economy” says Sylvain Lhôte, CEPI Director General. “The package needs to be kept on the right track in order to deliver the circular economy in and for Europe".


CEPI welcomes ENVI’s call to measure real recycling rates at the input to the final recycling process. To truly drive circularity in Europe, it is essential that material is only considered recycled once it enters the final production process and is actually reprocessed.


CEPI also supports the ENVI’s call for quality standards and traceability in the paper recycling chain that will enhance targeted investments and serve the efficient functioning of the secondary raw material market in Europe.


The reinforcement of separate collection will also drive quality recycling and boost circularity of Europe’s economy. In the past, authorities have used a loophole in the separate collection obligation to collect paper in co-mingled streams, undermining high quality recycling. CEPI is therefore concerned that the proposal to exempt scarcely populated areas from this obligation may unnecessarily open up a gap.


CEPI will further assess the extremely high gap between recycling targets of competing packaging materials, envisioned by MEPs.


Finally, CEPI is also encouraged by ENVI’s call on Member States to promote the use of bio-based recyclable packaging. “Leveraging on nature’s cycles for the circular economy is a welcome complement to the ambition of the Commission’s proposal” says Ulrich Leberle, CEPI Raw Materials Director.
 

For more information, please contact Ulrich Leberle at u.leberle@cepi.org or by phone at (+32) 2 62749 23


For press related enquiries please contact Ben Kennard at b.kennard@cepi.or by phone at (+32) 487 39 21 82
 

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10 Oct.2016

Circular Economy package - Joint statement by CEPI, EuRIC and FEAD

Leading federations representing the paper value chain call for the co-legislators to support the further increase of paper recycling and safeguard the “quantity” criterion in the definition of municipal waste.

The European Commission proposes to define municipal waste as mixed waste and separately collected waste from households and “mixed waste and separately collected waste from other sources that is comparable to household waste in nature, composition and quantity” .

A lot of the debate has focused on the quantity criterion. We believe that this is the only objective and measurable criterion. The quantity criterion is needed to clearly distinguish between municipal waste on one hand, and commercial and industrial waste on the other.

While paper from commercial and industrial sources is already collected and recycled at high levels, an untapped potential exists for household paper collection and similar sources, for which the waste directive is setting targets. If the quantity criterion is removed, the target for municipal solid waste will unduly include commercial and industrial waste and affect the accuracy of statistical data.

Moreover, the collection of commercial and industrial waste should not be financed and cross-subsidised by public funds, ultimately resulting in additional costs for taxpayers. In the absence of the quantity criterion there is a genuine risk that the scope of municipal waste is widened and therefore the focus is diverted from areas where the need to increase collection is the most acute. In order to ensure that all streams remain open to competition, instrumental to preserving cost-efficient and innovative waste markets, we support two key actions:

1. Maintaining the quantity criterion in the definition of municipal waste;

2. Clearly stipulate into the definition of municipal waste that it is neutral with regard to the public and private status “The definition of municipal waste (…) is neutral with regard to the public or private status of the operator managing waste and to the ownership of the waste”.

CEPI – The Confederation of European Paper Industries

The Confederation of European Paper Industries (CEPI) is a Brussels-based non-profit organisation regrouping the European pulp and paper industry and championing the industry’s achievements and the benefits of its products. Through its 18 member countries (17 European Union members plus Norway) CEPI represents some 505 pulp, paper and board producing companies across Europe, ranging from small and medium sized companies to multi-nationals, and 920 paper mills. Together they represent 23% of world production.

EuRIC – The European Recycling Industries’ Confederation

EuRic is the umbrella organisation for recycling industries in Europe. Through its Member Federations from 19 EU and EFTA countries, EuRIC represents today across Europe over:

  • 5,500 companies generating an aggregated annual turnover of about 95 billion €, including large companies and SMEs, involved in the recycling and trade of various resource streams;
  • 300,000 local jobs which cannot be outsourced to third EU countries;
  • An average of 150 million tons of waste recycled per year (paper, metals and beyond);
  • Recyclers play a key role in a circular economy. By turning wastes into resources, recycling is the link which reintroduces recycled materials into the value chains again and again.

FEAD – The European Federation of Waste Management and Environmental Services

FEAD is the European federation representing the European waste management industry. FEAD’s members are national waste management associations covering 18 Member States, Norway and Serbia. They have an approximate 60% share in the household waste market and handle more than 75% of industrial and commercial waste in Europe. Their combined annual turnover is approximately € 75 billion. FEAD represents about 3,000 companies with activities in all forms of waste management. These companies employ over 320,000 people who operate around 2,400 recycling and sorting centres, 1,100 composting sites, 260 waste-to-energy plants and 900 controlled landfills. They play an important role in the determination of the best environmental option for waste management problems.

 

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