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EU Circular Economy Package: Questioning the reasons for withdrawal

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EU Circular Economy Package: Questioning the reasons for withdrawal

The proposal by the European Commission to withdraw the Circular Economy Package from its 2015 Work Programme has produced a worrying climate of uncertainty. The arguments given for proposing the withdrawal call into question the legality, substance and democracy of the decision.
In short, we call on the European Commission to:
1) allow the current version of the circular economy package to follow the democratic co-decision process and address any improvements needed. Considering the loud condemnation of the withdrawal by both the Parliament and the Council, a withdrawal of this proposal by the Commission would be undemocratic.

2) Increase the level of ambition in a potential new proposal, should it unilaterally decide to withdraw the current one: increase number of jobs created, the environmental benefits to be gained, the cost savings to the public purse and the revenue to the repair and recycling sector. Any new proposal must provide nothing less than the benefits of the current proposal.

Furthermore, in the absence of any final formal decision by the Commission on its work programme, or any clear announcement on when it will do so, we present below the reasons given by the Commission for its withdrawal along with our counter-arguments.

1. The Circular Economy Package does not fit with the new jobs and growth agenda.

The current waste proposal has clear economic, social and environmental benefits at its core. The impact assessment estimates the creation of 580,000 jobs, the increase in annual turnover of the EU waste management and recycling sector by €42 billion, savings of €72 billion a year in waste management costs and a 27.5% reduction in marine litter by 2030. This would improve competitiveness of EU waste management and recycling sectors, and provide greater resource security with secondary raw materials being re-injected into the economy2. In addition, between 146 and 244 million tons of GHG emissions could be avoided by 2020 through reinforced application of the waste hierarchy, representing between 19-31% of the 2020 EU target.
These changes lead on from the Commission’s 2011 Raw Materials Communication and Resource Efficiency Roadmap, which highlight that, as worldwide demand for raw materials increases, greater efforts are necessary to boost recycling, reuse and repair in order to reduce the pressure on demand for primary raw materials, and reduce energy consumption and GHGs from extraction and processing.
Finally, the streamlining of present legislation would allow for increased legal certainty and make recycling legislation more easily enforceable, lifting regulatory and administrative burdens for SMEs as stated in a previous analysis by the Commission.

2. There would be ‘no foreseeable agreement’ between the European Parliament and the European Council

The Circular Economy Package fulfils obligations already agreed upon in the 7th Environmental Action Programme (EAP), adopted by the Council, the Parliament and the Commission in 2013. Within the 7th EAP the three institutions call for full implementation of existing waste legislation, the need for additional efforts to reduce waste generation and limiting landfilling and energy recovery to residual waste, while moving towards a lifecycle-driven ‘circular’ economy, with residual waste close to zero.
The reactions from MEPs and member states opposing the withdrawal, suggests that an agreement would have been reached, and that both institutions were eager to work further on the proposal. The threat of withdrawal has led a group of leading EU lawyers to state that “from a democratic point of view, it would be odd that an executive agency is able to depart so easily and so significantly from the Union lawmaker’s 2013 policy goals” and that “a definitive withdrawal from existing proposals would run counter to the general legal principle of loyal cooperation.”

3. EU law needs to be simplified

One of the stated objectives of the proposal is to simplify waste legislation. The proposal as it stands simplifies definitions, identifies one methodology instead of four and combines several directives into one in order to avoid confusion and administrative burdens. Therefore, any new circular economy proposal must not halt the already-started streamlining exercise of the current package.

4. European citizens want change as demonstrated by the election results. Therefore, the EU needs to focus on the big things that matter: jobs, growth and fairness in our societies.

It is true that the European election results signalled a desire for things to be different. However there is no evidence that citizens want a cut back on environmental laws. The Eurobarometer poll 4165 conducted over the period Europe was going to the elections (mid 2014) showed that 74% of Europeans believe that environmental protection can boost economic growth, and 56% believe that the EU is not doing enough to protect the environment. The more recent Flash Eurobarometer 3886 from June 2014 also highlighted that 86% of people think that the impact of more efficient resource use would be positive on the quality of life, bring economic growth (80%), as well as on employment opportunities in their country (78%). Most of them consider that reducing waste and sorting recyclable waste at home (51%) and in industry and construction (50%) would make the biggest difference.

Withdrawal of the Circular Economy Package from the current co-decision process makes no sense and constitutes a huge waste of the Commission’s, Council’s and Parliament’s resources.


Statement in support of maintaining the current circular package_22 Jan 2015_FINAL


Is the EU missing the boat in ship recycling? CW2YQMTPZCNE

The EU could be generating jobs and local economy whilst preventing pollution and destruction in the global south if it got its policies right in shipbreaking.

Every year, about 1,000 ships are sent for breaking so that their steel and some of their contents can be recycled. Most of the ships contain hazardous materials such as asbestos, mineral oil, PCBs, mercury, etc. However, despite high unemployment rates and empty shipyards in Europe more than 200 European ships were sent for breaking on the beaches of South Asia in 2011, and the number of ships to be broken in 2012 is expected to beat all records.

This is because instead of selling their ships to recycling facilities that enforce strict downstream waste management, such as in the EU, Turkey, Canada, the US and Mexico, most shipowners prioritize maximum profits and sell them to the shipbreaking yards of India, Pakistan and Bangladesh.

Out of all ships sent for breaking every year, 40% are owned by European companies, whereas only 8%are flagged in the EU. The Commission legislative proposal aims at regulating only EU-flagged ships sent for breaking, thus only covering 8% of all end-of-life vessels.

The European Commission claims that there are not enough recycling facilities in the OECD -let alone the EU- to recycle these vessels and hence it permits that recycling takes place in unacceptable conditions in the global south. According to the NGO Shipbreaking Platform the claims from the European Commission are based on a flawed impact assessment, and it proves that in the OECD there is enough recycling capacity. The problem is clearly that the prices for proper recycling are a lot higher than those in the global south where recycling takes place in facilities considered unsound to health and the environment. The Basel Convention and EU Waste Shipment Regulation ban such export of hazardous waste to poorer, non-OECD countries, but this is easily circumvented, notably by reflagging ships.

The result of the commission’s assessment, published in March, was that the lack of recycling capacity meant the waste shipment regulation should no longer apply to ships (COM (2012) 118).

But NGO Basel Action Network (BAN) published a report proving that the commission “failed wholeheartedly” to consider both active and dormant recycling capacity in North America. Alongside EU and Turkish sites, this could easily handle the 1.64 million tonnes of old ships from the EU each year.

The final decision is in the hands of the EU member states in the council of ENVI ministers and some member states such as Germany, Finland, Denmark, Estonia,  Italy, Holland,The Netherlands, Ireland and Sweden are supporting the existing ban of export of end-of-life ships to the global south. It is sad to see how countries such as Spain with record unemployment levels and empty shipyards don’t see the opportunity to convert the old shipyards into ship recycling facilities. It would help Spain, it would help Europe and it would help the people in the south suffering from the European ecological dumping.

The Zero Waste movement stands committed to proximity principle and extended producer responsibility together with the principles of local economy and environmental justice. For these reasons it advocates for the construction of ship recycling clusters in Europe that boost depressed European economic sectors whilst removing the ecological and social burden from the global south. The European Commission should mantain the ban on the export of end-of-life vessels.



Toxic Europe: How much is the EU doing to fight illegal waste trade – How much can Zero Waste do?

The recently awarded documentary “Toxic Europe” is a good piece of investigative journalism which uncovers a lot of dirty truths about waste management in Europe.
The documentary reveals how at least 225 million tons in the whole of the European Union escape legal treatment –it could be a lot more- and how that is linked to the low prices offered by the illegal dealers which sometimes is 4 to 5 times cheaper than the legal prices.


Indeed, the trafficking of waste traficking to internal EU borders or abroad faces lots of challenges; firstly, contrary to normal crimes, there is no interest from the parties to denounce the illegal practices because they all benefit from it. Secondly the waste flows mixed within the trade routs is so big that it is almost impossible to control. According to the documentary the customs of Antwerp, one of the biggest EU harbours, control only 2% of the waste that comes in and 1% of the waste that goes out (!).


It is badly needed that the EU takes over the control of its own borders if it is to manage illegal waste trade but once again the EU lacks the resources to do so and the member-states refuse to do so. Without more control at the borders –whose workers are very often are infiltrated by the mafia- the only way to stop waste from Germany, Denmark, Belgium, Italy, etc from being shipped abroad is by managing it locally with transparent and traceable systems. And this can only be done if we change our relation with our waste; if we separate it at source and it is properly collected and measured it is very difficult that it can later “disappear”.

So we can see how Zero Waste is not about only about sustainability it is also about democracy and rule of law. A Zero Waste strategy makes all waste very visible which makes traceability possible and effectively fights ilegal practices. Whenever waste is not separately collected or the authorities claim that they make waste “disappear” what it means is that it will end up either in an incinerator/landfill or scaping the legal routes..