Policy Recommendations on the Circular Economy Package

Published: 27 October 2014

Policies & Issues: Environment

The efficient use of resources in both, production processes and products manufactured by Orgalime industries is innate, as resource inputs account for almost 50% of total production costs in our sector. Any proposed action, including legislative, in the area of resource efficiency and circular economy needs to build on industry driven action and focus on securing our sector´s global competitiveness and its future contribution to Europe´s jobs and growth agenda. 

We agree with the importance that the Circular Economy Package (further on CEP) reserves to trade and research policy, to support the key objective of securing continuous and reliable access to raw materials and fair competition for European manufacturing, while making our own products and processes in Europe ever more intelligent and efficient. In addition, we support the suggested landfill ban and recommend its immediate implementation. 

Improving and better harmonising national reporting obligations on the EU´s waste policy acquis can also bring benefits. Nevertheless, we wish to remind that these obligations apply, and need to continue to apply, on Member States level, including the newly suggested article 16.5 of the WEEE Directive 2012/19/EU. 

However, we call upon European regulators to assess whether and in how far CEP is indeed fit to support Europe’s growth and jobs agenda in an open minded manner, and to strive for truly sustainable, market driven results, especially in the following areas:

  • CEP promotes waste policy objectives and end of life product measures in an isolated manner instead of pursuing a holistic approach in the interest of overall sustainability (environmental, economic and social). This risks disturbing today´s sensible EU product design policy approach of the Ecodesign Directive, which is based on cost efficiency, product functionality, environmental improvement from a life cycle perspective, and affordability for consumers. The existing Ecodesign Directive should be preserved, while imminent conflicts of different (product) policy objectives, including between the promoted resource efficiency parameters themselves (see annex of this paper) must be resolved.  Ecodesign should not be reduced to “design for recycling” but remain holistic to secure the ongoing implementation of the Ecodesign Directive on some 50 product groups of Orgalime´s industries.
  • Linking product and waste policy via a new article 8.2 of the Waste Directive risks to fragment the EU internal market and to promote free riding: product requirements need to be measurable, enforceable and fully harmonised at EU level, which is inevitably at stake with end-of-life product requirements.
  • The newly suggested binding definition of “Extended Producer Responsibility (EPR)” and minimum requirements for such EPR-schemes build on the outdated understanding of “waste as a cost”. Instead, these should address today´s reality that in our sector “waste has become a value” and that, as such, “other actors than producers” are increasingly involved in waste management activities for economic reasons. The challenge therefore is to ensure that the EU policy acquis and standards are also respected in these other routes and their actors. In addition, these new EPR definition and requirements rule into Member States´ sovereignty in the area of waste management.

Related Position Papers

Environment: Orgalim response to the public consultation on the RoHS evaluation [6 December 2019]

Environment: Evaluation of Directive 2011/65/EU (“RoHS”): Improving implementation in a Circular Economy context [6 December 2019]

Environment: The European technology industries’ priorities for the sustainable use and management of water in Europe [14 November 2019]

Environment: Orgalim's response to a public consultation on sustainability requirements for batteries [27 August 2019]

Waste policy: Joint industry comments on modulating producers’ financial contributions for Waste Electrical and Electronic Equipment [26 July 2019]

Eunomia study in support of developing Guidance for Extended Producer Responsibility (EPR) Schemes: Comments on modulation of producers’ financial contributions [12 March 2019]

Orgalim response: Consultation by Technical Expert Group on Sustainable Finance [25 February 2019]

Feedback on the usability of the taxonomy - Orgalim response [25 February 2019]

Orgalime response to consultation on RoHS Substance Review Methodology [21 December 2018]