CEWEP · Trade and business associations · DE
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Within the review of requirements for packaging and other measures to prevent packaging waste, CEWEP would like to highlight the importance to maintain a holistic approach and to strike the right balance between policy goals (e.g. waste prevention, recycling, air quality, non-toxic environment). This balance is extremely important to ensure that the overall aim of tackling environmental, health and climate impacts is achieved, avoiding the risk of undermining the overarching sustainability objectives. The environmental objectives of reducing packaging and restrict their placement on the market only if they are recyclable/compostable are not yet supported by a robust analysis of the impacts of these choices. Allowing substances of high concern, such as POPs or heavy metals, in the recycling system can increase the environmental and health impact of recycled materials.
POPs or heavy metals, in the recycling system can increase the environmental and health impact of recycled materials. It should not be forgotten that a one-sided focus on increasing recycling volumes and masses can lead to quality deterioration and to dissipation of toxic substances in recycled materials. Instead of only increasing recycling volumes, the quality of the recyclables and the elimination of toxic substances in consumer goods should be the first priority in the transition towards a circular economy. This aspect has been investigated in the last years with regards to mechanical recycling but it is not really known for new techniques, e.g. to chemical recycling. It is important to mention that energy recovery of packaging waste that cannot be recycled (because of e.g.
…recycling. It is important to mention that energy recovery of packaging waste that cannot be recycled (because of e.g. contaminants that would pollute the cycle of a circular economy) does not mean that the resource is lost, but that both energy and materials (from bottom ash) are recovered. Waste-to-Energy plants (incineration with energy recovery) convert the non-recyclable waste into energy that is delivered back to society, including the recycling and manufacturing/chemical industry, and into solid residues that are partly recycled as secondary metal or as construction material and partly stabilized/solidified to be stored in a safe sink. Residues from sorting and recycling activities that are sent to Waste-to-Energy (WtE) are prevented from contaminating recyclates and from ending up as litter or in water bodies.
…to Waste-to-Energy (WtE) are prevented from contaminating recyclates and from ending up as litter or in water bodies. They are treated in a safe and highly controlled way in WtE plants carefully monitoring everything that goes in and out from the process. This way, WtE fulfils in the Circular Economy (CE) the role of a gatekeeper enabling material recovery from non-recyclable waste, while keeping recovered materials free from toxic substances. In addition, WtE plants need to respect the most stringent environmental legislation in terms of emissions and protection of the environment as a whole, especially considering that the sectorial BAT Conclusions have just been published, with the inclusion of the most updated standards.
…that the sectorial BAT Conclusions have just been published, with the inclusion of the most updated standards. Considering the fact that WtE plants help substituting energy from fossil fuels and materials such as metals that have a high climate impact, it does not seem accurate to include as an environmental impact “the reduction in health impacts from air pollution from the incineration of unrecycled packaging waste”. In a sustainable CE, the most suitable treatment option for the different waste types generated is determined by economic, environmental, as well as societal and health criteria. In order to allow for a level playing field and for a holistic approach, calculation methods for the contribution that a specific process provides to the overarching objectives should be consistent. CEWEP would like to Ref.
…that a specific process provides to the overarching objectives should be consistent. CEWEP would like to Ref. Ares(2021)150697 - 07/01/2021 recall that within the review of the Waste Framework Directive the Commission proposed an harmonization of definitions and methodologies to calculate the contribution of recycled materials to the relative targets. Following this approach would be the most beneficial in terms of better regulation but also to ensure that the recycling industry working with waste streams coming from municipal and similar waste would not have to abide by different standards than the industry working with packaging waste. Simplified or theoretical approaches would not provide the same trust in the accountability that the EU has to guarantee when dealing with the health and wellbeing of the environment and citizens.
CEWEP feedback on the European Commission’s Review of the requirements for packaging and other measures to prevent packaging waste Within the review of requirements for packaging and other measures to prevent packaging waste, CEWEP would like to highlight the importance to maintain a holistic approach and to strike the right balance between policy goals (e.g. waste prevention, recycling, air quality, non-toxic environment). This balance is extremely important to ensure that the overall aim of tackling environmental, health and climate impacts is achieved, avoiding the risk of undermining the overarching sustainability objectives. Allowing substances of high concern, such as POPs or heavy metals, in the recycling system can increase the environmental and health impact of recycled materials.
POPs or heavy metals, in the recycling system can increase the environmental and health impact of recycled materials. It should not be forgotten that a one-sided focus on increasing recycling volumes and masses can lead to quality deterioration and to dissipation of toxic substances in recycled materials. Instead of only increasing recycling volumes, the quality of the recyclables and the elimination of toxic substances in consumer goods should be the first priority in the transition towards a circular economy. CEWEP supports the general objective for the revision laid down in the roadmap and would like to stress that the review must be carried out in line with the policy objectives of the European Green Deal and the new Circular Economy Action Plan. It is important to mention that energy recovery of packaging waste that cannot be recycled (because of e.g.
Plan. It is important to mention that energy recovery of packaging waste that cannot be recycled (because of e.g. contaminants that would pollute the cycle of a circular economy) does not mean that the resource is lost, but that both energy and materials (from bottom ash) are recovered. Waste-to-Energy plants (incineration with energy recovery) convert the non-recyclable waste into energy that is delivered back to society, including the recycling and manufacturing/chemical industry, and into solid residues that are partly recycled as secondary metal or as construction material and partly stabilized/solidified to be stored in a safe sink. Residues from sorting and recycling activities that are sent to Waste-to-Energy (WtE) are prevented from contaminating recyclates and from ending up as litter or in water bodies.
…to Waste-to-Energy (WtE) are prevented from contaminating recyclates and from ending up as litter or in water bodies. They are treated in a safe and highly controlled way in WtE plants carefully monitoring everything that goes in and out from the process. This way, WtE fulfils in the Circular Economy (CE) the role of a gatekeeper enabling material recovery from non-recyclable waste, while keeping recovered materials free from toxic substances. In addition, WtE plants need to respect the most stringent environmental legislation in terms of emissions and protection of the environment as a whole, especially considering that the sectorial BAT Conclusions have just been published, with the inclusion of the most updated standards.
…that the sectorial BAT Conclusions have just been published, with the inclusion of the most updated standards. Considering the fact that WtE plants help substituting energy from fossil fuels and materials such as metals that have a high climate impact, it does not seem accurate to include as an environmental impact “the reduction in health impacts from air pollution from the incineration of unrecycled packaging waste”. In a sustainable CE, the most suitable treatment option for the different waste types generated is determined by economic, environmental, as well as societal and health criteria. In order to allow Ref. Ares(2020)4125275 - 05/08/2020 for a level playing field and for a holistic approach, calculation methods for the contribution that a specific process provides to the overarching objectives should be consistent.
…methods for the contribution that a specific process provides to the overarching objectives should be consistent. CEWEP would like to recall that within the review of the Waste Framework Directive the Commission proposed an harmonization of definitions and methodologies to calculate the contribution of recycled materials to the relative targets. Following this approach would be the most beneficial in terms of better regulation but also to ensure that the recycling industry working with waste streams coming from municipal and similar waste would not have to abide by different standards than the industry working with packaging waste. Simplified or theoretical approaches would not provide the same trust in the accountability that the EU has to guarantee when dealing with the health and wellbeing of the environment and citizens.
…accountability that the EU has to guarantee when dealing with the health and wellbeing of the environment and citizens. Brussels, 6 August 2020 Contact : [email protected]; www.cewep.eu CEWEP, Confederation of European Waste-to-Energy Plants, is the umbrella association of the operators of Waste-to-Energy (incineration with energy recovery) plants, representing about 410 plants from 23 countries. They make up 80% of the Waste-to-Energy capacity in Europe. Its members are committed to ensuring high environmental standards, achieving low emissions and maintaining state of the art energy production from remaining waste that cannot be recycled in a sustainable way.