The European Recycling Industries’ Confederation (EuRIC) represents the recycling industry at a European level. Gathering the vast majority of national recycling  federations from EU/EEA Member States, the Confederation represents about 5.500+ recycling companies – from market leaders to SMEs – generating an aggregated annual turnover of about 95 billion € by treating various waste streams such as household or industrial & commercial waste including ferrous and non-ferrous metals, end-of-life vehicles (ELVs), electronic waste (WEEE), packaging (paper and plastics), end-of-life tyres or textiles. As a result, EuRIC represents the industries that are working tirelessly to transform everyday (and specific) waste streams into high-quality and high-value Raw Materials from Recycling (RMR). These materials directly substitute many extracted raw materials, and therefore represent a drastic reduction in product embedded Greenhouse Gas (GHG) emission and environmental impacts. To achieve the goals defined by the European Commission, we believe it is essential to adopt an approach to waste shipment that necessarily distinguishes high quality RMR from lower quality waste.

EuRIC thanks the European Commission for publishing the recent proposed revision of the Waste Shipment Regulation (WSR). While EuRIC strongly supports the key objectives of the legislative revision namely combatting illegal shipments or improving the internal market for Raw Materials from Recycling (RMR)2, the European recycling industry would like to express its grave concern on the consequences of the proposed measures on the EU’s recycling industry. The one-size-fits-all approach vested in the Commission’s proposal would, if endorsed, result in devastating consequences on the competitiveness of EU’s recycling industry.

This paper provides the position of the European Recycling Industry, which outlines how future Waste Shipment Legislation must be designed with the objective of enabling the Circular Economy, rather than dismantling it. The paper will focus on the three key objectives of the proposed revision of the WSR: enabling intra-EU material recovery, reducing the export of EU waste challenges to third countries, and tackling illegal waste shipments & implementation.