The questions come from the Brussels-based Impact Assessment Institute (IAI), which has produced a scrutiny study for the Commission on the data accompanying last December’s Circular Economy proposals.
In a draft of the document, the IAI observes that plans for a 65% by 2030 recycling rate across the EU, do not take into account the varying levels of progress accomplished by EU Member States to date.
According to the IAI the Commission struggled to find data that is “complete, accurate and consistent between different Member States” and that some of the proposals would have been based on “judgements and assumptions”.
The organisation concluded: “These difficulties also raise concerns about the reliability of the data, especially given the projections of outcomes over long timescales. Small errors in the baseline data could be amplified into significant errors in final outcomes predicted by the Waste Management Model.”
IAI adds that benefits for individual Member States would be ‘optimised’ by tailored targets and measures that take into account the “multiplicity” of different conditions. The organisation has recommended assessment of the impacts of options for targets that “differentiate sufficiently” between Member States.
Speaking to letsrecycle.com Simon Godwin managing director of the IAI, said: “The main issue is the lack of sufficient differentiation between the conditions in Member States in relation to the targets that are set. It was originally a one size fits all target, now it is two sizes, but in reality there are 27 different sizes. Some are going to have a lot easier time than others.”
IAI has also criticised the structure of the legislative proposals when compared to the legislative package put forward by the Commission in 2014, under the stewardship of the former Environment Commissioner Janez Potocnik.
IAI claims that many of the new proposals had been ‘reordered and renumbered’ when compared to the 2014 package, which it claimed: “made it very difficult to gain a clear understanding of the overall history of the proposals, especially the difference between the 2014 and 2015 versions.”
“Clarity and transparency would have been greatly improved if all the proposed changes had been in equivalent format in both 2014 and 2015,” the organisation added.
IAI’s draft study is currently out for peer review – with the organisation seeking views from experts by 8 July – after which a final assessment will be submitted to the European Commission. A draft copy was distributed to trade bodies and think tanks earlier this month.
Details of IAI’s draft report on the proposals, which is currently out for peer review and due to be finalised in July, have emerged as EU environment ministers – including Defra’s Rory Stewart – meet in Brussels to discuss a number of policy areas, including the Circular Economy Package.
Discussion of the Circular Economy proposals is currently ongoing within the EU, with MEPs considering revisions to the package put forward by the chair of the European Parliament’s Environment Committee Simona Bonafe earlier this month. The Parliament will seek to agree on a position by November.