At the same time, there is still a potential of waste that is not collected but incinerated or landfilled. A significant volume of recyclable waste is collected in
Europe but is exported to other continents to be recycled/recovered/treated there. This development poses challenges to the closing of the recycling loops and therefore the European goal of becoming a recycling society.
With this position paper, the undersigning recycling sectors (see box) would like to explain the functioning of the recycling value chain and the challenges that the recycling sectors face today. They make concrete proposals for policies that would be needed to optimize the functioning of the recycling chains and thereby their contribution to a resource efficient Europe.
The recycling value chain
Recycling is more than the collection of recyclable waste materials. It is the result of a series of steps which are part of the recycling value chain: collection, pre-processing (including when appropriate dismantling), processing (including extraction of contained material from recyclable waste), processing into a new product/material. These value chains can slightly differ from one sector to another. The specificities of the materials and value chains may call for sector-specific policy approaches to improve recycling and increase the resource efficiency of the European economy as a whole.
Recycling is a highly efficient way of reintroducing valuable materials into the economy. It delivers real benefits as it:
- Addresses resource efficiency
- Lowers energy consumption and hence CO2emissions significantly
- Reduces environmental impacts on water and air
- Decreases EU's dependency on raw material imports
- Helps move from waste management to material management
- Creates and maintains jobs in Europe.
Europe has come a long way to improve its recycling rates and has thereby reduced landfilling of waste. More recycling can be achieved provided the appropriate framework conditions are in place.
Challenges for Europe's recycling industries
The undersigning sectors represent key European Industries using secondary raw materials as a substantial part of their feedstocks. There is still a potential for them to increase their recycling activities, even if it varies between the sectors for different reasons.
The obstacles to producing a higher share of paper, plastic, man-made fiber, ferrous and non-ferrous metals products from secondary raw materials are the following:
- Insufficient and contradictory policy support for closing the loops
- Subsidies for the use of recyclable and renewable material for energy recovery
- Insufficient recyclability requirements for converted products
- Suboptimal end-of-life collection schemes
- Shortage of secondary raw material due to exports to non-European countries partly due to illegal shipments of waste
- Lack of level playing field worldwide
- Technological hurdles to recycle increasingly complex products
- Landfilling of recyclable waste
- Inconsistencies in legislation in the field of waste, products and materials.
The challenges for the different sectors are multiple; one of them however is a threat to the entire European recycling industry: the massive exports of secondary raw materials outside the EU. Secondary raw materials exported outside the EU represent not only a loss of the material (often poor efficiency of the recovery process with regard to the intended raw material) but also a loss of the embedded energy: producing new products based on virgin/primary materials only is, in general, more energy consuming hence impacting negatively on the EU's climate and energy goals. In the case of metals, for example, recycling provides substantial energy savings -- for some industries up to 95% energy saving -- making complete productive chain of metal products a low-impact generative process in which primary process route (from virgin materials) is balanced by secondary process route (from recycled materials). The same applies to staple fiber spun out of PET bottle flakes, compared with virgin PET. Additionally, exports of wastes and secondary raw materials may lead to a higher environmental burden in a global perspective.
The significant exports of European secondary raw materials are facilitated by:
- A strong demand for resources from emerging markets
- Relatively cheap east bound shipping costs
- Substandard environmental management of recycling processes outside Europe
- Insufficient control at borders
- Lack of quality of the collected material.
In the undersigning sectors' view, such exports are in opposition to the European Union's objective of a resource efficient Europe.
Concrete proposals for policies needed to optimize recycling
To optimize recycling in Europe from our current levels, targeted policies are needed. To enable the European industries using secondary raw materials to recycle even more, to take account of the full value chains and to close the recycling loops, the undersigning European recycling industry sectors:
- Call for a sound implementation and enforcement of existing legislation. A sound implementation of the waste Directives/Regulation would ensure:
- separate collection at source (separately from each other) of paper, metal, plastics and glass by 2015;
- that recycling outside Europe would take place with environmentally sound management of secondary raw materials as is the case in Europe;
- the proximity principle of recycling secondary raw materials in efficient plants at high quality close to their source whenever possible and relevant.
- Call for better enforcement of the Waste Shipment Regulation with a view to curbing illegal shipments of waste. The work of Impel and customs authorities should be supported, e.g. through a distinction of second-hand goods and new goods at customs so as to help them improve target controls.
- Call on the European Commission to propose a ban on landfilling of recyclable waste.
- Call on the European Commission to include recyclability criteria for the product groups covered by the eco-design directive today and product groups that might be covered in the future. Optimized recyclability of products would:
- contribute to resource efficiency and lower environmental impacts;
- take a value chain approach to the minimisation of environmental impacts at all stages of the life cycle;
- facilitate industrial ecology;
- Call for actions to ensure that recycling takes place in efficient facilities rather than in sub-standard facilities, e.g., by a certification scheme for pre-processors and recyclers making sure recycling takes place in an "environmentally sound manner" (ESM).
- Call on the European Commission to stimulate producer responsibility and explore new concepts or tools in full cooperation with the stakeholders concerned so as to avoid a shift in impact and ensure that the instrument delivers.
- Call on the European Commission to investigate the substantial subsidies given by some third countries, such as China, to secondary raw materials using companies with respect to their compatibility with WTO rules and take appropriate measures.
- A reminder that requirements such as recycled content should be considered cautiously as a general tool, as they may lead to inefficiencies in the supply chains (e.g., a paper producer located in a remote forest area would have to import paper for recycling from urban areas to ensure its product meets the recycled content requirements, hence leading to additional transport and lack of paper for recycling elsewhere). The same applies to non-ferrous metals that can be recycled again and again without losing their properties so the objective should be to ensure that they are recycled at the end-of-life. However, they can be an effective tool in specific sectors.
- Call for a recycling strategy aiming at recycling secondary raw materials with the highest material purity and efficiency. When appropriate, recycling should take place close to the source. The high investments needed for metal recycling imply that the priority should be to ensure efficient recycling as opposed to proximity.
- Call for effective recognition of the benefits of recycling in other policies than waste policy, such as the energy policy. Similarly to the waste hierarchy, other policies should promote the cascading use of raw material to support added value and job creation before using the resources as a source of energy. Energy efficiency and resource efficiency must become key criteria in raw materials impacting policies.
- Call for adjustment of policies and legislation to avoid inconsistencies and double or contradictory legislation that hinders recycling processes in order to maximize the use of waste and secondary raw materials, and as such saving natural resources.
Recycling is a key driver for resource efficiency. To optimize recycling in Europe from our current levels, targeted policies are needed. The proposals listed above would enable the European industries using secondary raw materials to recycle even more, thereby supporting the full value chains, closing the recycling loops and contributing to the EU 2020 targets and the objective of a resource efficient Europe.