Cepi Position on EU-wide End-of-Waste criteria for paper

Oct 14, 2021

Cepi recalls that used paper and board products are considered as recycled only when they are reprocessed into new pulp, which will be used to produce recycled paper.

Considering the situation of the recycling of paper and board in the European Union, Cepi wants to recall that:

  • Fiber-based product materials have already reached one of the highest, if not the highest recycling rate, in the EU (73.9% in 2020), without an EU-wide EoW application.
  • The paper industry and its suppliers have been pioneers in setting high quality criteria by defining as early as 2002 an EU-wide standard listing the expected quality criteria to be fulfilled by paper for recycling to be accepted in paper mills.
  • 12 million tonnes of paper for recycling have circulated in the EU internal market in 2019, that was 22% of the total paper for recycling collected. This demonstrates that the paper for recycling market is already well functioning, and not subject to any significant burden.

The paper industry does not deem necessary the application of an EoW status for paper-based products, as it is not the appropriate regulatory tool to help increase the quantity and/or quality of paper for recycling. To achieve the EU-wide recycling targets set in EU legislation (Waste Directive and Packaging and Packaging Waste Directive), the main objective should be to increase the collection of paper for recycling. EoW is not the mechanism to encourage citizens to better sort waste at source in their daily life.

However, in case EU-wide EoW criteria for paper would be developed, the following conditions have to be met: 

  • The final recycling of paper for recycling (PfR) shall continue to take place at the paper mill, where the calculation methodology and calculation point for the recycling rate are set according to the Waste Directive[1] and secondary legislation[2] respectively. Under current legislation, the calculation point for paper and board is where sorted paper does not undergo further processing before entering a pulping operation[3]. The calculation point must remain at the input to the final recycling process, irrespective of the EoW status of PfR.
  • The legal measure needs to clarify that paper that has reached end of waste status, is paper that has been recovered from the waste stream, and as such has obtained secondary raw materials status, but is yet to be recycled by the pulper of the paper mill (proposed term: recovered paper for recycling).
  • PfR can only cease to be waste if it complies with the specifications set in the EN 643 standard and is sent directly to a paper mill for final recycling (without further mixing). This needs to be declared by a statement of conformity, issued by the sorting plant.
  • A quality management system needs to be in place to verify that PfR with EoW status complies with the EN 643, as well as with product related legislation. This system should be based on statistical evidence and on standards already in place (e.g. prEN 17085, prEN 17545) for test methods and quality specification for paper and board. A simple visual control shall not be accepted. This quality management system shall be audited by an external independent verifier.
  • Special paper grades (EN 643 Group 5) that need to be treated in specialised recycling systems should keep waste status and not be considered as EoW; this is to ensure they are not mixed with other EN643 groups before the input to the final recycling process at the paper mill.
  • EoW status can only be achieved for paper for recycling originating from separate collection. Separate collection of paper and board should not only be from residual waste, but also from other recyclables such as plastic, metal or glass.

Rationale:

Paper for Recycling (PfR) is the main raw material for the production of new paper and board. In 2020, 56 million tonnes of PfR were collected, out of which 49.6 million tonnes were recycled by the paper industry in the EU 27, Norway, Switzerland and the United Kingdom. The remaining PfR has been imported by third countries for recycling in the paper industry in these countries. According to the European Paper Recycling Council, paper and board recycling rate has reached a very high level of 73,9% in 2020, with flows already travelling through Europe without significant constraints. Evidently, EoW status has not been a necessary step for this waste stream to achieve this exceptionally high level of performance. It can also be noted that the paper industry and its suppliers were forerunners in defining, as early as 2002, an EU-wide recognised standard (EN 643) defining the quality specifications expected from paper and board for recycling.

Some Member States or regions have put in place measures for PfR to cease to be waste. However, PfR is only recycled once it changes its physical properties and undergoes a reprocessing operation which takes place in the pulper of the paper mill. Therefore, according article 6 §1 of the Waste Directive, EoW cannot happen for sorted PfR as that waste stream has not “undergone a reprocessing” operation before entering the paper mill.

As the paper production processes are usually originally designed to use fresh fibre and/or PfR, Cepi does not believe that the EoW status increases industrial demand for the material nor does it decrease environmental impacts. Paper recycling has achieved a high level of circularity without EU-wide EoW criteria based on the fact that recycling takes place in the same industry, which produces the basic raw material for the products to be recycled. Therefore, recycling is already taken into account from the start, at the design-phase of products and throughout the cycle of use, collection and sorting.  The clear advantage of EU-wide EoW criteria over conflicting national EoW criteria would be to secure the Internal Market, by assuring that EoW status for a specific material would uniformly apply to all Member States, when traded in the Internal Market.


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