European Commission public consultation on waste shipments – review and assessment ofrevision of EU rules


The European Commission’s Circular Economy Action Plan seeks to strengthen Europe’s lead position when it comes to circular economy. Finnish companies are at the forefront of creating new solutions for the circular economy but request for predictable regulation, a well-functioning internal market and cost-efficient implementation.

The European Commission has published a new Action Plan proposing a common strategy for Europe supporting the growth and competitiveness of the circular economy. Under the umbrella of the Green Deal, the Circular Economy Action Plan aims to create new sustainable economic growth while providing solutions to combat climate change and resource scarcity. Key sectors in the new plan include construction and demolition, food, textiles, transport and electronics.

The treatment of secondary raw materials and the definition of waste in circular economy legislation are among the pressing issues. Companies are concerned about the availability of recycled raw materials and the smooth cross-border transportation of the secondary raw materials. The message is clear: recycled raw materials should not be treated as waste as long as they don’t pose a health or safety threat. It is important to agree on clear rules that enable companies to offer circular economy products and services.

The aim of the Action Plan is also to strengthen the EU’s own capacity to take care of its waste. Industry is pleased with the proposals and continues to encourage the elimination of regulatory bottlenecks in order to achieve a genuine circular economy business. Efficient markets play a key role. EK requests the EU Commission to provide enabling and encouraging legislation to turn this vision into reality. The current regulatory bottlenecks need to be addressed in order to accelerate the circular economy.

To boost the secondary raw materials market, economies of scale are crucial both for collection and management of waste into secondary raw materials. The Waste Shipment Regulation (WSR) is a key piece of legislation in enabling safe and traceable transboundary movements of waste. At the same time the regulation is a well-recognized bottleneck for the development of the circular economy within the EU single market. The WSR and the operational use of the text currently restrict the full utilization of resources in the internal market.

Inconsistencies in interpretation and differences in enforcement of the WSR in Member States complicate the movement of waste and secondary raw materials within the single market. Administrative burden, lack of further harmonization, frequent delays of notification procedures, lengthy procedures in renewals–to name a few–all cause additional costs for secondary raw materials. When these unnecessary costs are added to the value chain of secondary raw materials, incentive for recycling and reuse of secondary raw materials is reduced. EK calls for streamlining, simplifying, and unifying of the waste shipment procedures as crucial and necessary measures.

There are several focus areas in the Action plan which is relevant from WSR perspective. Plastics, batteries and accumulators are a fast growing sector and would benefit immensely from economies of scale. Another interesting example is the textile sector, which currently recycles only less than 1% of the used textiles globally. The Commission will therefore publish a comprehensive textile strategy after first consulting industry and stakeholders.

Separate collection of waste textiles must be organized in EU countries by 2025 at the latest. An example of Finnish industry´s commitment to circular economy of textiles is the completely new type of textile recycling facility to be built in Paimio, Finland, where waste textiles can be utilised as a new raw material. Following from this, the formerly untapped textile waste will now create the first industrial-scale aftermarket.

Collection alone will not solve the challenges related to textile waste, but the material will also need handlers and recoverers. The annual capacity of a full-size textile recycling plant is estimated at around 100 million kilograms, so the amount of textile waste in each Member State is not sufficient for cost-effective treatment and recovery of textile waste. From the point of view of promoting the circular economy of textiles, it is important that the transfer of waste for recycling is smooth within the EU.