Czech Business Today

The EESC prepared its opinion on the access to secondary raw materials since the Raw material strategy obtains ever-growing attention and raises a high concern, mainly in the sectors with a high rate of recycling. 

The analyses explain the current situation and future scenarios that could lead to serious supply and demand imbalances on the secondary raw materials market. Large volumes of collected secondary raw materials are currently being exported although they are badly needed in the European basic and process industries. This trend seriously jeopardises employment in all the process industries. The pressure of excess volumes of collected waste from the existing dedicated collecting systems is often relieved by simply selling off those collected categories of waste indiscriminately, without any additional processing and without securing final utilisation within the EU. 

It is obvious that numerous specific regulations governing recycling have not been framed coherently. They tend to focus on individual, isolated aspects of collection and recycling and do not take account of the market forces at work in the systems and processes. The REACH Regulation is also causing problems in some recycling industries because there is no clear distinction between the end-of-life goods (waste) and second-hand goods. The conflict between the market forces and the existing regulatory framework should be analysed in detail. 

One possible suggestion could be to apply export duties to protect against the risk of losing valuable materials. Such measures would obviously have to comply with the WTO rules. The EU should possibly negotiate emergency terms with the WTO, setting clear and transparent conditions for export restrictions/duties on wastes of strategic importance. An option would be to agree on flexible recycling targets depending on actual market developments. 

Recycling should be supported by improving collecting infrastructure, creating legal certainty and an equal level playing field and by removing unnecessary administrative burdens. All the individual elements of the EU Climate Change Policy should take into account the environmental benefits of secondary raw materials, any inconsistencies should be avoided: for example, the EU-ETS does not reflect energy and carbon savings resulting from the use of recoverable raw materials in other industrial and construction sectors and unnecessarily burdens these sectors with additional costs. More info here. 

Josef Zbořil,
Rapporteur for the opinion on the raw materials of the EESC and Member of the Board of the Confederation of Industry CR