EESC Corner: Towards a Circular Economy

On 2 July 2014, the European Commission published a package of proposals comprising: the communication Towards a circular economy: A zero waste programme for Europe – COM(2014)398 final – plus four more items on waste, recycling, etc.

The key document of this initiative is the communication “Towards a circular economy” which introduces an attempt to put in a legal framework the flagship initiative of the EC on resource efficiency. Given the ambitious targets that EU has set with regard to waste management, any revision of the legislative framework must be aimed at strengthening the industrialization of the sector and the competitiveness of the market to increase the overall efficiency of the services and the enhancement of waste potential. However, such concerns are not adequately addressed by the current Commission’s proposal and, obviously, it would be better to take the package back, facilitate health checks and revise the most critical elements of this initiative.

There are numerous serious question marks, among them, for instance:

Comparable data throughout the EU28 are insufficient, even do not exist.
Extended Producer Responsibility (EPR): the correct implementation of this principle should not entail unnecessary extra-costs or create an unequal distribution of such costs within the industry chain, as well as distort effects in terms of competitiveness.
Harmonization of rules: the proposal put forward by the Commission according to which Member States will be given the possibility to define their own criteria for the design of packaging, and for targets for prevention and recovery should not hinder the free circulation of goods at EU level.
Revision of the targets and of the calculation methodologies: the proposal put forward in the Packaging Directive to revise both the targets and the methodology for calculation of the same, would generate further uncertainty for the obliged entities.
Waste Hierarchy: the proposal put forward in the Packaging Directive to exclude the possibility, under certain conditions, to derogate from the waste hierarchy may generate problems to implement an effective and efficient waste management.
Delegated acts: the proposal to give the Commission the power to adopt “delegated acts” should be limited to an opportunity and must be taken forward with the full involvement of the relevant sectors.

If any targets are to be adopted, they should be measureable throughout the 28 Member states, and they should motivate to reduce waste occurrence and handling the waste in the most efficient way. Such targets should be: