The joint letter has been sent by the six bodies making up the Trade Association Group – the Anaerobic Digestion and Bioresources Association (ADBA), Chartered Institution of Wastes Management (CIWM), Environmental Services Association (ESA), Institution of Civil Engineers (ICE), Renewable Energy Association (REA) and the Resource Association.
It has been sent ahead of the new package of legislation due for publication by the Commission next month (December 2), which will refresh existing EU laws including the Waste Framework and Landfill Directives – dubbed the ‘Circular Economy’ package.
Mr Timmermans has promised that the new measures will be ‘more ambitious’ than those drawn up by the former Environment Commissioner Janez Potocnik, which were dropped by the Commission last year.
But, the Trade Association Group has expressed concerns that the new legislation will not include sufficient ‘pull’ measures, which would encourage the use of recycled materials in new products.
Targets
Early indications from Brussels suggest that the package will include a new recycling target – albeit reduced from the 70% rate proposed in the 2014 package – as well as restrictions on which materials can be sent to landfill.
But, there has been no indication of any desire to see a move toward incentivising the use of recycled material in new products (see letsrecycle.com story).
In its letter, the Trade Association Group stated: “In particular, we wish to emphasise to you the importance of the role of pull measures as a central plank of the revised package. Supply side actions have served us well in many respects to date, but they will be insufficient for the challenges ahead. We all share the ambition for a more circular economy, but we do not see the delivery of a circular economy coming purely from the operation of the market.”
‘Pull measures’
Pull measures which have previously been suggested to the Commission for inclusion in the package include recycled content requirements for some products or lower VAT rates for second hand goods or those with recycled content.
The letter adds that while the Commission is seeking ‘lighter touch’ regulation, the Circular Economy should be seen as “an exception to the Commission’s general rule, because to deliver the strong environmental and economic benefits of a circular economy requires a long term regulatory framework and market interventions that will stabilise and enhance the viability of increasing recycling.”
The letter from the six UK trade bodies follows a similar appeal by the European Federation of Waste Management and Environment Services (FEAD) last month, whose president David Palmer-Jones called for targets to remain harmonised at EU level, with ‘longer transition periods’ and ‘additional support’ for some less advanced Member States (see letsrecycle.com story).
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