The Environmental Services Association (ESA), Resource Association and Renewable Energy Association (REA) all submitted responses to the Commission’s consultation on the upcoming legislation – which is due to be unveiled by the Commission later this year.

The 12-week public consultation, which was launched in May, set out to investigate the main policy options to be considered before the new package of measures is finalised (see letsrecycle.com story).
The UK resource trade bodies have submitted a comprehensive list of options that they believe should be adopted, with general consensus for the EU to introduce ‘more harmonised’ definitions and methods of calculating waste statistics.
ESA has proposed minimum recycled content requirements for selected products, as well as minimum green public procurement requirements to boost purchase of recycled materials.
Other suggestions include a zero rate of VAT on second hand goods, eco-labelling rules to incorporate indications of a product’s recyclability, and tougher waste crime enforcement.
‘Priority’
Jacob Hayler, executive director of ESA, said: “Another ESA priority is for the European Commission to improve statistics on raw and secondary material flows, which means clarifying and harmonising definitions and calculation methodologies. A more consistent approach to statistics will help member states compare performance in a more meaningful way and learn from best practice.”
The Resource Association meanwhile has called for mandatory source separation of biowaste, reducing contamination and improving the quality of secondary raw materials.
The Association would also like to see ‘clear long-term ambition’ on recycling targets and the banning of recyclables to landfill and, in the longer-term, to incineration.
Ray Georgeson, Resource Association chief executive, said: “We know that the circular economy is about much more than recycling, but getting the collection and processing of secondary raw materials in the best order possible to underpin the emergence of a more circular economy has to be a paramount priority for the Commission’s revised waste legislation.”
REA

REA has also backed separate collections of biowaste – which includes household and commercial garden, food and kitchen waste – and has set a prospective deadline of 2020 to make it compulsory.
In addition, REA has called for ‘strict limitation’ of incineration without recovery to non-recyclable waste to begin in 2020, and ongoing allowance of gasification and pyrolysis of the biodegradable fraction within residual waste from municipal and industrial sources.
One factor in REA’s call for separate biowaste collections is the prevalence of opt-in green waste collections for households.
The REA position paper states: “In the UK reduced tonnages of green (garden) waste are collected as a number of local authorities have changed from separately collecting this waste under general taxation for their services to households to extra, separate charging for households that opt-in to separate collection of their green (garden) wastes.
“More local authorities are likely to make this change unless legal requirements and/or policy drivers support separate collection of this resource at no extra charge to householders.”
Responses
The EU Commission is to assess the responses to the consultation, which closed on August 20, before laying out the policy options later in the autumn.
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