The BDE Federal Association of the German Waste, Water and Circular Economy has reacted with scepticism to the results of the EU Parliament's vote on the Waste Shipment Regulation. The association is particularly critical of the regulations on plastic shipments.
On 17 January 2023, the plenary session of the European Parliament approved the Environment Committee's report on the European Commission's proposal for a revision of Regulation 1013/2006 on shipments of waste (Waste Shipment Regulation), thereby adopting new rules for waste shipments. The focus was on the import and export of plastic waste within and outside the EU.
„With their decision last Tuesday, EU parliamentarians passed regulations that severely restrict, if not make it impossible, to ship waste. The new regulations are contrary to the plan to develop the European economy into a circular economy.“
Peter Kurth, BDE President
BDE has also criticised the regulations, which not only affect plastics, but also also all other materials that are exported for recycling to third countries that are not EFTA states. According to the association, the regulations for this waste are tantamount to a de facto export ban.
In the opinion of the BDE, the general ban on the export of plastic for recycling outside the EU or EFTA states is contrary to international law. According to this law, trade restrictions for reasons of environmental protection are generally permissible, which is why the Basel Convention on Environmental Protection only unmixed and fully recyclable plastics are shipped to non-OECD third countries.
In the BDE's view, the tightening of the rules on the shipment of plastics and other waste within the EU adopted by Parliament is also problematic, persistent organic pollutants (POPs) included.
In future, they should independent of the concentration value of the pollutant are subject to the notification procedure, i.e. the procedure of prior notification. This means that even green-listed waste is now always subject to the notification procedure for intra-European shipments for recovery, regardless of the quantity of pollutants.
The BDE is strongly opposed to this, because in practice this regulation would lead to almost all shipments of waste for recycling within the European Union would have to be notified. Implementing the decision would therefore also be a blatant contradiction to the goal of reducing bureaucracy in the EU internal market by revising the Waste Shipment Regulation.
The association therefore strictly rejects a general subjection of waste containing POPs to the notification procedure regardless of the actual pollutant content. At best, this would a limit value-based regulation based on the POP Regulation is conceivable. Annex IV of the POPs Regulation defines the limit values for substances above which a waste is considered POP waste and therefore may no longer be recycled but must be disposed of. Waste that complies with the limit values in Annex IV is not considered POP waste and must be recycled. They may therefore also be shipped within the EU for recycling.
BDE President Peter Kurth: „The resolutions passed by the EU Parliament are an obstacle to the establishment of a functioning circular economy; What's more, if the Parliament's decisions are implemented, this would be the end of the circular economy for plastics. The parliamentarians' vote has the potential to destroy the recycling structures and markets for plastics within the EU. A notification requirement for all waste that contains even a trace of a POP - and especially waste that is to be sent for recycling - completely ignores reality, as almost all plastic waste is marginally affected by a POP. The Council must now correct the EU Parliament's vote and send a clear signal in favour of a functioning circular economy in the EU. What's more, markets for recycled raw materials do not end at the EU's external borders. That is why an export ban to third countries must also be prevented!“
Source: BDE
