Open Letter to Jessika Roswall: Advancing End-of-Waste Criteria for Recovered Paper
To the kind attention of: Ms Jessika ROSWALL
Commissioner for Environment, Water Resilience and a Competitive Circular Economy
Brussels, 24 April 2026
Advancing End-of-Waste Criteria for Recovered Paper
Dear Commissioner Jessika Roswall,
On behalf of Recycling Europe, we would like to draw your attention to the urgent need to establish EU-wide end-of-waste (EoW) criteria for recovered paper.
Paper recycling is one of Europe’s most successful circular economy value chains, delivering resource efficiency, CO₂ savings, and industrial resilience for decades. Yet it is increasingly under pressure due to regulatory fragmentation and administrative burdens, reflected in a patchwork of national end-of-waste criteria, inconsistent interpretations of waste shipment rules, and diverging procedures across Member States – creating legal uncertainty, increasing costs, and hindering intra-EU trade and investment.
The situation is becoming more critical with the implementation of the new Waste Shipment Regulation. In the absence of harmonised EU criteria, this risks creating additional complexity in practice and unnecessary barriers within the Single Market for compliant recovered paper, despite it being a non-hazardous material stream widely traded across Europe.
Importantly, the development of EU-wide EoW criteria for recovered paper has not yet started, despite being identified by the Joint Research Centre (JRC) as a priority waste stream[1] that would benefit strongly from such criteria. While stakeholder alignment remains important, experience with other material streams shows that the development of EU end-of-waste criteria can progress in parallel with ongoing industry discussions. In the case of recovered paper, the absence of progress on this file is increasingly difficult to reconcile with the objective of ensuring a well-functioning market for this secondary raw material.
Recovered paper already meets the conditions set out in Article 6 of the Waste Framework Directive to cease to be waste: it is commonly used for specific purposes, benefits from a well-established market, complies with technical requirements, and does not lead to adverse environmental or health impacts. The EN643 standard further provides a harmonised and recognised quality framework across the European paper value chain.
To address the current situation, Recycling Europe calls for the development of harmonised EU end-of-waste criteria for recovered paper, based on the existing industry standard, EN643.
In parallel, greater clarity is needed on the treatment across Member States of materials that have achieved end-of-waste status under duly notified national criteria. In this context, guidance from the Commission on the practical implementation of such cases, including under the Waste Shipment Regulation, would be highly valuable.
Establishing such criteria is essential to provide legal certainty, reduce administrative burden, and unlock further investments in recycling, while reinforcing the recognition of recovered paper as a key secondary raw material in support of the Circular Economy Act and the Clean Industrial Deal.
We would welcome continued engagement with the European Commission and remain at your disposal to provide further technical input from the sector.
Best regards,
Julia Ettinger José Andrés Martín
Secretary General, Recycling Europe President, Recycling Europe Paper
CEO, MC2 Recycling
[1] European Commission, Joint Research Centre (2022), “Scoping possible further EU-wide end-of-waste and by-product criteria” (link).
