2021/0367(COD) · In Force
146 submissions from 116 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 160 submissions on this file. Shown here: the 146 from organizations. Not shown: 3 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 11 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
114 submissions from industry — companies and their trade associations — against 27 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 4.2 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice. An identical text filed by several organizations counts once: 1 submission here repeats one text word for word and is folded into it.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 17 Jan 2022 — it ran from 19 Nov 2021.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 25 of 146 submissions.
· · filed 17 Jan 2022 · source
The Portuguese Plastics Industry Association (APIP) welcomes the intention of the European Commission to review the Regulation on shipments of waste (WSR). In this context it is crucial to simplify and reduce burdens linked to its implementation (less bureaucratic, less time-consuming).
1. ZWAI supports the revision of the WSR rules. We welcome the decision to reduce waste exports from the EU to developing countries. 2. ZWAI supports the assertion that wastes diverted from export can have a positive economic value and reduce dependence on primary raw materials, supporting the change to a more circular economy. 3.
· · filed 17 Jan 2022 · source
Eurima welcomes the revised Waste Shipments Regulation by the European Commission which better reflects the principles of circularity. The Waste Shipments Regulation (WSR) is a crucial step for the recovery of “post-consumer” waste that is generated during renovation or demolition/deconstruction project.
· · filed 17 Jan 2022 · source
The Minderoo Foundation is a philanthropic organisation based in Perth and Amsterdam. Through our No Plastic Waste Initiative we seek to end plastic leakage to nature and maximize circularity in the plastics economy by 2030. We welcome the revised Waste Shipment Regulation (WSR) as a concrete step towards addressing the plastic waste issue.
· · filed 17 Jan 2022 · source
The BDE Bundesverband der Deutsche Entsorgungs-, Wasser- und Materialwirtschaft e.V. is the largest association of German waste disposal, raw material, recycling and water management, with around 750 member companies. For BDE member companies, the Waste Shipment Regulation is one of the main building blocks for a successful circular economy.
Filed in German · English published by the European Commission
ITAD, the German Association of Waste-to Energy Plants welcomes the direction the European Commission is taking with the revision of the Waste Shipment Regulation (WSR). The EU has the capacity to treat its own waste in the best way possible. ITAD also welcomes the ban on intra-EU shipments for disposal, in order to optimally retrieve secondary raw materials.
EUROSHORE INTERNATIONAL is the association of port reception facilities. It gathers 36 members from 16 countries in Europe, Africa and Middle East collecting, treating and recycling or recovering waste from ships under the IMO legislation on preventing pollution from ships, the MARPOL 73/78 Convention.
A3M contribution to the next European Waste Shipment Regulation January 17th 2022 A3M, Alliance des Minerais, Minéraux et Métaux (Alliance for Minerals, Ores and Metals), brings together the French Industrial Forerunners of the French and European downstream sectors to ensure their reindustrialization, strategic autonomy, innovation and environmental transformation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
VEOLIA welcomes the revision of the Regulation on shipments of waste As a company carrying out waste management activities across Europe, VEOLIA is directly impacted by the Waste Shipment Regulation (WSR). The review process is a timely initiative as there are a number of concerns that need to be addressed in order to speed up the implementation of the legislation and to respond to future European and international…
Almagro, 22 – 4ª planta 28010 MADRID (España) Tfno.([phone removed] Fax. ([phone removed] Waste Shipment Regulation (WSR) proposed legislative revision Substantial changes needed to protect Europe’s recycling industries 1 7 J a n u a ry 20 2 2 The Spanish Federation of Recovery and Recycling (FER) is the spanish association which defends the interests of the spanish recycling sector in different economic, technical…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eurometaux, representing the EU metals producers and recyclers, recognises the publication of the WSR legislative proposal as a very important delivery of the EU Green Deal, connecting to the EU Circular Economy by securing the availability of the secondary raw materials and to the Zero Pollution Action Plan by ensuring that waste are treated in an Environmentally Sound Manner (ESM).
· · filed 17 Jan 2022 · source
Zero Waste France would like to welcome the progress made by this proposal to revise Regulation (EC) No 1013/2006 on shipments of waste. However, the association must point to a number of shortcomings which undermine the ambition of a European Union (EU) engaged in waste reduction and the development of a genuine circular economy.
Filed in French · English published by the European Commission
17 January 2022 Response to the Commission Proposal for the Revision of the Waste Shipments Regulation Municipal Waste Europe welcomes the Commission proposal for the revision of the Waste Shipments Regulation and the way in which it addresses the issue of illegal shipments as well as the creation of a digital notification system which is simultaneously accessible by all Member States and adaptable to existing…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
GEIR is the European Waste Oil Re-Refining Industry Association. GEIR member companies are active throughout Europe supporting the collection of waste oils and regenerating these back to valuable base oils. GEIR represents 80% of the waste oil regeneration industry in Europe. Waste oils represent the largest amount of liquid, non-aqueous hazardous waste in the world.
· · filed 17 Jan 2022 · source
FRANCE – APE Europe is the non-packaging plastics products’ association for agriculture and acts for a sustainable, profitable production, and a reliable agri-plastics’ end of life management. Our mission is to provide farmers and growers with sustainable solutions for their production and the end of life management of agri-plastics, especially by the creation of dedicated National Collection Schemes where missing.
France — Professional Association, created in 1958, the CPA is responsible for the integrated management of plastics for agriculture and is responsible for the financial management of the end of life of 98 % of the volumes used in France.
Filed in French · English published by the European Commission
FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the possibility to provide feedback on the proposed revision of the Waste Shipment Regulation (WSR).
EuRIC thanks the European Commission for publishing the recent proposed revision of the Waste Shipment Regulation (WSR). EuRIC strongly supports the key objectives of the legislative revision however would like to express its grave concern on the consequences of the proposed measures on the EU’s recycling industry. This is described below.
In 2016, export of waste from the EU to third countries outside the EU amounted to around 40 million tonnes, around 20% of the global export of waste. At the same time, approximately 13 million tonnes of waste were imported into the EU 1.
· · filed 17 Jan 2022 · same text as 1 other organization · source
As representatives of social enterprises active in re-use, repair and recycling, as well as Work Integration Social Enterprises specialised in the inclusion of disadvantaged groups on the EU job market, RREUSE and ENSIE welcome the Commission’s proposal to revise EU rules on waste shipments.
Statement 17 January 2022 EuroCommerce feedback to the consultation about the proposal for a regulation on shipments of waste and amending Regulations (EU) No 1257/2013 and (EU) No 2020/1056 Retailers and Wholesalers welcome the proposal to revise the Waste Shipment Regulation, because it should enable more circular business activities.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 17 Jan 2022 · source
Regulation (EC) No 1013/2006 on shipments of waste (VVA) is one of the key building blocks for the successful use of secondary raw materials and thus for the substitution of primary materials. Only if reliable, enforceable and practical rules are in place for companies to transport and trade waste for the production of secondary raw materials can they be used throughout the whole area in often global value-added…
Filed in German · English published by the European Commission
The European Tyre and Rubber Manufacturers’ Association (ETRMA), representing tyre and rubber goods producers in Europe, supports the overall goals of the revision of the Waste Shipment Regulation. The ETRMA is ready to support the EC with ideas and suggestions on how to develop an EU waste management that is more efficient and meets the goals of the green deal.
· · filed 17 Jan 2022 · source
The Rethink Plastic alliance welcomes the proposal made by the European Commission to revise Regulation (EC) No 1013/2006 on Shipments of Waste of the European Parliament and of the Council of 14 June 2006, also referred to as the Waste Shipment Regulation (WSR).
Eurits [the European Union for the Responsible Incineration and Treatment of Special waste] welcomes the revision of the Waste Shipment Regulation (WSR) (Regulation 1013/2006). As we have previously commented during the evaluation of the WSR, Eurits believes that in general the WSR is a good piece of legislation which does not need fundamental revision but rather consistent implementation and enforcement.
DIGITALEUROPE welcomes the proposal for the revision of the EU Waste Shipment Regulation WSR. We believe the proposal has the potential to enable the movement of secondary raw materials, to avoid environmental dumping and burdensome shipment of secondary raw materials and accelerate the circular economy. We support the EU’s focus on enabling the shipment of secondary raw materials within the Single Market.
MOL Group welcomes the European Commission’s proposal on a revised Waste Shipment Regulation to ensure the safe handling of wastes, to preserve the environment and human health, and to contribute to the transition to a competitive circular economy in the EU.
Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the proposal for a revision of the Waste Shipment Regulation (WSR) and appreciates the opportunity to provide comments, which can be found attached.
As representatives of social enterprises active in re-use, repair and recycling, as well as Work Integration Social Enterprises specialised in the inclusion of disadvantaged groups on the EU job market, RREUSE and ENSIE welcome the Commission’s proposal to revise EU rules on waste shipments.
In general Euromines welcomes the WSR proposal. Some comments we would like to mention are: • Current WSR (1013/2006) contains 25 kg threshold applicable only to waste designed for laboratory analysis. The new text is positive as it increases the threshold to 150 kg and applies it also to shipment waste for experimental treatment tests. However, 150 kg threshold might not be enough for e.g.
BIR stresses major contradictions impacting the Circular Economy objective and requires more data to be collected before action BIR (*), the global federation of recycling industries, fully supports the existing EU legislation that organizes the separate collection, recycling and recovery of wastes.
with regard to the proposal to amend Regulation (EC) No 1013/2006, the PolieCo Consortium has always pursued the objectives of combating illegal exports of plastic waste that is often polluted and to countries where environmental legislation is less careful to protect the health of citizens.
Filed in Italian · English published by the European Commission
The Confederation of European Paper Industries - Cepi welcomes the Commission legislative proposal amending the existing Waste Shipment Regulation. We endorse the policy maker’s intention to put an end to the export of our waste challenges outside the EU and support EU policy on waste shipments promoting recycling in the Union.
· · filed 17 Jan 2022 · source
The advanced waste treatment facilities, EEW and AVR, welcome the direction the European Commission is taking with the revision of the Waste Shipment Regulation (WSR). The EU has the capacity to treat its own waste in the best way possible. EEW and AVR also welcome the ban on intra-EU shipments for disposal, in order to optimally retrieve secondary raw materials.
· · filed 17 Jan 2022 · source
The Finnish Technology Industries promotes competitiveness and operational preconditions of technology industry companies, the largest and most important export sector in Finland. Technology industry comprises five sub-sectors: electronics and electro technical industry, mechanical engineering, metals industry, consulting engineering and information technology industries.
Cefic welcomes the European Commission proposal on Waste Shipment Regulation to ensure the safe handling of wastes, to preserve the environment and human health by fighting against illegal imports and exports of waste within, from and to the EU, and to contribute to the transition to a competitive circular economy in the EU.
Shipments of Wastes Destined for Disposal Within the EU: The Group fully supports the proposal to prohibit the shipment of wastes destined for disposal, both within and outside the EU, except for in some specific circumstances, as this ultimately contributes to a circular economy and will help the EU achieve the commitments it signed up to through the Global Methane Pledge before the COP26 event.
The European aluminium industry welcomes the Commission’s proposal for the revision of the Waste Shipments Regulation and considers it an important first step towards the modernisation of the EU’s waste legislation, which is pivotal in the transition to a resource-efficient, low-carbon and overall sustainable circular economy.
Sehr geehrte Damen und Herren, anliegend erhalten Sie die Stellungnahme der drei deutschen Recyclingverbände bvse, BDSV und VDM zu dem Vorschlag der Kommission für eine Überarbeitung der Verordnung über die Verbringung von Abfällen (WSR). Für eine wohlwollende Berücksichtigung der Belange der Recyclingbranche wären wir dankbar. Mit freundlichen Grüßen [name removed] Sekundärrohstoffe und Entsorgung e.V.
· · filed 17 Jan 2022 · source
Dear Ladies and Gentlemen, We would like to thank you for the opportunity to comment on the proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on shipments of waste and amending Regulations (EU) No 1257/2013 and (EU) 2020/1056. Please find enclosed our statement. If you have any questions, please do not hesitate to contact us.
January 17th, 2022 Finnish Environmental Industries’ feedback on the EC proposal for a revised Waste Shipment Regulation The Association of Finnish Environmental Industries represents the waste management companies and recycling industry in Finland.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
January 17th, 2022 Finnish Environmental Industries’ feedback on the EC proposal for a revised Waste Shipment Regulation The Association of Finnish Environmental Industries represents the waste management companies and recycling industry in Finland.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Ladies and Gentlemen, I am enclosing the statement on the revision of the Waste Shipment Regulation (WSR) of the three German recycling associations BVSE, BDSV and VDM. We would be grateful for your sympathetic consideration of the views of the recycling industry as presented. Yours sincerely [name removed] Legal Advisor Federal Association for Secondary Raw Materials e.V.
POLYECO S.A. COMMENTS ON: Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the shipments of waste and amending Regulations (EU) No 1257/2013 and (EU) No 2020/1056. [2021/0367 (COD)] Article 4, par.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Position Paper Revision of the Waste Shipment Regulation Publication date: 17 January 2022 The steel industry welcomes the release of the revision of the Waste Shipment Regulation by the European Commission. However, significant improvements are necessary to ensure effectiveness of the revised rules in contributing to the objectives of the EU Circular Economy Action Plan and the EU Green Deal.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
NRK Recycling Contribution of NRK Recycling about the consultation “Waste transport — evaluation and documentation of EU rules”. General: Recycling of plastic waste streams is crucial to achieve a circular economy. NRK recycling endorses the need to tackle legal shipments of waste. Export of waste to inspected facilities Export of collected and sorted plastic waste is of great import to recycling companies.
Filed in Dutch · English published by the European Commission
The steel industry welcomes the release of the Waste Shipment Regulation revision by the European Commission. However, significant improvements are necessary to ensure effectiveness of the revised rules in contributing to the objectives of the EU Circular Economy Action Plan and the EU Green Deal.
In principle, the VOEB warmly welcomes the further development of waste shipment legislation and the emphasis on the circular economy. The rational use of waste (recycling, use as secondary raw materials) should be promoted from both environmental and economic points of view.
Filed in German · English published by the European Commission
The working group “Fast-Track Notifications” is an initiative coming from the North Sea Resources Roundabout, envisioned to accommodate several secondary resource streams or cases, working out practical and scalable solutions to the barriers encountered in the transboundary shipment of secondary resources. ‘Fast-Track Notifications’ was one of the cases of this International Green Deal NSRR.
The steel industry welcomes the revision of the Waste Shipment Regulation (AbfVerbV) and the publication of a draft by the European Commission. However, substantial changes are needed to ensure the effectiveness of the over-ridden rules when moving outside the EU in order to safely achieve the objectives of the EU Circular Economy Action Plan and the EU Green Deal, e.g.
Filed in German · English published by the European Commission
NABU welcomes the planned stricter regulation of waste shipments, in particular with regard to plastic waste, the export of which poses significant environmental risks. The revision of the EU Waste Shipment Regulation will make it more difficult in future to export plastic waste to countries with little developed recovery structures.
Filed in German · English published by the European Commission
EUCOPRO ASBL Rue Vilain XIIII 53-55 B-1000 Brussels Phone: [phone removed] Fax : [phone removed] EUCOPRO Interest Representative Identification number: 75111426376-95 14th January 2022 Proposal for a regulation on shipments of waste and amending Regulation n°1257/2013 and n°2020/1056 COM (2021) 709 final of 17th November 2021 EUCOPRO comments EUCOPRO (European Association for Co-processing) is an association…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FNADE’s Feedback Waste shipment regulation review proposal FNADE, the French association for waste management and environmental services welcomes the European Commission’s proposal to review the Waste Shipment Regulation. FNADE used to ask the Commission to introduce technical improvements in order to reduce the too long delays for notification procedure.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Eramet, a global French mining group, is a key player in the extraction and transformation of metals. Eramet supports the transition to a carbon neutral economy by developing activities strategic for Europe to sustain its leadership and autonomy in this transition, including nickel, cobalt, lithium mining extraction, refining, and recycling around the world.
APK AG welcomes the European Commission revision of the Waste Shipment Regulation (WSR) aiming at ensuring safe handling of waste, preventing illegal imports and exports and transitioning to a competitive Circular Economy for plastic waste in Europe.
EUROBAT welcomes the proposal on Waste Shipment Regulation published on 17 November 2021 by the European Commission. It is of paramount importance for the EU internal market to have a clear regulation that allows, clarifies and facilitates waste shipment inside, and outside of the EU, given that certain environmental and socio-economic conditions are met.
Hazardous Waste Europe (HWE) welcomes the European Commission’s proposal for the revision of the Waste Shipment Regulation (WSR). We are very pleased to see that most of the main issues raised by HWE have been addressed with concrete and appropriate proposals: -adaptation of the amount of waste in case of experimental treatment trials, -clarification of the timing and deadlines regarding the requests for…
· · filed 14 Jan 2022 · source
Svenska järn och Metallskrothandlareföreningen (The Swedish Iron and Metal Scrap Traders' Association) supports the initiative for a revision of the Ordinance on waste shipment regulation, WSR. Recycling plays a key role in achieving the EU's climate-neutral and circular economic goals.
· · filed 14 Jan 2022 · source
Confederation of Danish Industry (DI) and Waste and Resource Industry, Denmark, support a revision of the Waste Transport Regulation. We find it crucial for the circular economy in the EU: • For manufacturing companies: The legislation should support take-back solutions and sourcing of secondary raw materials across national borders.
· · filed 14 Jan 2022 · source
We welcome strict control and monitoring of waste streams and shipments within the EU and imports and exports to and from the EU. As a global medium-sized company as a supplier of sorting machines for the recycling industry, we run a test centre at our headquarters, which can capture sorting processes and processes very closely to reality.
Filed in German · English published by the European Commission
In its proposal for new rules on the shipment of waste, published on November 17th, the EU-Commission pursues three main goals, which, in principle, are supported by VCI: - Shipments of waste for preparation for reuse and recycling in the EU are facilitated - The EU does not export its waste challenges to third countries - Illegal shipments of waste are more effectively addressed Especially the measures to…
Plastics Europe welcome the revision of the Waste Shipment Regulation (WSR). We recognise the EU Commission efforts to simplify the procedural framework governing shipment of waste within the Europe Union and countries of the European Economic Area (EEA) and to strengthen enforcement.
APK AG welcomes the initiative of the European Commission to define a framework and conditions for the use of plastic recyclates in food contact materials. As the current revision still contains some challenges to innovation, we would like to contribute the following points from the perspective of a material recycler that recently scaled a novel, physical and solvent-based recycling technology. 1.
Proposition de règlement du Parlement Européen et du Conseil relatif aux transferts de déchets et modifiant les règlements (UE) nº 1257/2013 et (UE) 2020/1056 POSITION DU GROUPE SALINS DESCRIPTION DE LA SITUATION ACTUELLE L’usine de Varangéville (54) du Groupe Salins produit des blocs composés à destination de l’alimentation animale.
Filed in French · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Please find enclosed input from the Federation of Norwegian Industries to the proposal that revises the regulation on shipments of waste. Multilateral cooperation: Article 30 in the proposal for a new regulation concerns border area agreements and the possibility for MS to conclude bilateral agreements to make the notification procedure for shipments of specific waste flows less stringent.
· · filed 14 Jan 2022 · source
Shipment of mixed municipal waste (MMW) In the current waste shipment regulation (2006/1013), article 3.5 states: Shipments of mixed municipal waste (waste entry 20 03 01) collected from private households, including where such collection also covers such waste from other producers, to recovery or disposal facilities shall, in accordance with this Regulation, be subject to the same provisions as shipments of waste…
As part of Fortum corporation, the Fortum recycling & waste business area support the objectives of the proposal for a revised Waste Shipment Regulation. Fortum submitted a reply to EC's Public Consultation on the WSR in June 2020 and is pleased to see that several of the company's policy objectives have been addressed in the EC's proposal.
· · filed 13 Jan 2022 · source
France — Collective non-profit organisation set up in 2001 on a voluntary basis by the whole agricultural profession, A.D.I.VALOR (Farmers, Distributors, Industriels for the Recovery of Agricultural Waste) organises in France the collection and recycling of agrosupply waste: Empty packaging, used plastics and hazardous waste. A.D.I.VALOR is recognised by the Ministry of Ecology and the Ministry of Agriculture.
Filed in French · English published by the European Commission
WEEE AUDITS welcomes a revision of the Waste Shipment Regulation and want to address the following topics: - The preferable recovery operation according to the waste hierarchy, defined in article 4 in the WFD – Preparing for re-use. - The alignment with the Waste Framework Directive (WFD) - Terminology issues, and - Producer´s responsibility that are described in the added file.
The proposal for a revision of the Regulation on cross-border shipments of waste is an improvement to the current Regulation. Specific mention is made of the digital exchange of documents and the shortening of the notification period for shipments. Nevertheless, there are still areas for improvement while maintaining the objective of the Regulation.
Filed in Dutch · English published by the European Commission
In particular, we are concerned about the reduced time for notification of waste receipt. For many storage operations, it will not be possible to determine the net weight of the waste within one day of delivery, especially for hazardous waste which should be stored in packaging.
· · filed 7 Jan 2022 · source
The Association of Municipal Enterprises (VKU) e.V. welcomes the European Commission’s proposal to amend the 2006 Waste Shipment Regulation: It is right and necessary to further restrict exports of plastic waste in particular. On the one hand, exports, especially to distant third countries, are harmful to the climate, as emissions occur during transport.
Filed in German · English published by the European Commission
The EEB welcomes the revised text of the Waste Shipment Regulation. It integrates clear improvements compared to existing law. E.g: a ban by default on shipments for disposal, even within EU; a ban by default to export to non-OECD countries of both hazardous and not hazardous waste; a ban for export untreated, mixed Municipal Solid Waste; a monitoring system for export towards OECD countries; the obligation to audit…
Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europe’s industrial workforce at European Level. IndustriAll Europe is an organisation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and…
· · filed 8 Dec 2021 · source
Dear Sir or Madam, we are pleased to comment on the issue of “shipment of waste”. We are a medium-sized company that manufactures machinery for the recycling industry worldwide. With regard to the issue of ‘shipment of waste’, we would like to ask that exceptions should be introduced, in particular for machinery manufacturers with experimental installations.
Filed in German · English published by the European Commission
I'd like to draw your attention on art 17 comma 3 of the regulation EC nr 1013/2006 where : quote 3. where such changes involve competent authorities other than those concerned in the original notification, a new notification shall be submitted Unquote bring to your attention that this art.
· · filed 8 Apr 2020 · source
ZERO welcomes the inception impact assessment (IIA) of the WSR stressing the intention to stop exporting waste outside the EU and revisit existing rules. According to the IIA, “International trade in waste has increased considerably. In 2016, four times more waste were traded across international borders than in 1992 and this waste had a value of around 100 billion euro.
· · filed 8 Apr 2020 · source
We welcome the inception impact assessment of the WSR stressing the intention to stop exporting waste outside the EU and revisit existing rules. As stated in the EU Circular Economy Action Plan, review of EU rules on waste shipments will aim at restricting exports of waste that have harmful environmental and health impacts in third countries.
Waste Shipment – Revision of EU rules Tesla input to the European Commission’s inception impact assessment General remarks: Tesla welcomes the European Commission’s intention to review the EU’s Waste Shipment Regulation (WSR) in light of the new Circular Economy Action Plan and the European Green Deal.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 8 Apr 2020 · source
SSAB EMEA AB supports the initiative of a revision of the Waste Shipments Regulation, WSR. The transition to a more Circular Economy within EU, with enhanced high standards of safety for human health and environment, must work together. The evaluation by the Commission in January 2020, already lists many obstacles as hinders for a smooth ongoing transition to a more Circular Economy within the EU.
· · filed 8 Apr 2020 · source
Arnika, a member of International Pollutants Elimination Network (IPEN), demonstrated severe contamination originating from waste exports with highly toxic persistent organic pollutants and other toxics in local communities of Africa and South East Asia. These toxics than contaminate excessively their food chain.
The BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirt— schaft e.V. agrees on key points with the results of the impact assessment. A functioning market for secondary raw materials is essential for a functioning circular economy. Secondary raw materials must be able to move within the EU while respecting high standards without major bureaucratic hurdles.
Filed in German · English published by the European Commission
FNADE welcomes the initiative of the European Commission for revising the WSR and supports, generally speaking, any initiative allowing to move towards more circular economy and recycling, even if in the case of the WSR it will have a limited effect due to the aim of the regulation. The latest evaluation of these procedures’ regulation has pointed out its relevance since its implementation.
Meeting the challenge of Proper Management of Hazardous Waste Waste Shipment Regulation: Inception Impact Assessment Eurits comments, April 2020 Eurits welcomes the Inception Impact Assessment (IIA) on the revision of the Waste Shipments Regulation (WSR) (Regulation 1013/2006).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The upcoming revision of the Waste Shipment Regulation comes at a critical moment and on the heels of significant changes to the EU and international policy landscape on the circular economy and plastic waste. As the Commission is well aware, cross-border trade in plastic waste is notoriously opaque, characterised by a lack of transparency, traceability and accountability across the value chain with many…
· · filed 8 Apr 2020 · source
Technology Industries of Finland thanks of the possibility to comment Commission’s plan, revision of Waste Shipment Directive, in its early stage as Inception Impact Assessment is. Finnish companies are at the forefront of creating new solutions for the circular economy, but request for predictable regulation, a well-functioning internal market and cost-efficient implementation.
Exports are crucial for a well-functioning EU waste market. FEAD underlines that WSR is and must remain a regulation used for shipment procedures and must not become a policy instrument for new objectives. While it must be consistent with the objectives of the Circular Economy, its adaptation must not be detrimental to safety nor traceability and must ensure that formalities are appropriate regarding the…
6 April 2020 Brussels Feedback from Zero Waste Europe (ZWE) and the European Environmental Bureau (EEB) on the Inception impact assessment of Waste Shipment Regulation (WSR) We welcome the inception impact assessment (IIA) of the WSR stressing the intention to stop exporting waste outside the EU and revisit existing rules. According to the IIA, “International trade in waste has increased considerably.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The NGO Shipbreaking Platform fully supports the initiative to review the current Regulation (EC) No 1013/2006 on shipments of waste (WSR) with a view to align it with the Circular Economy Action Plan of the European Commission, and to that end ensure: • coherent and strong measures against the illicit trafficking of hazardous waste and reversal of the current environmental and heath related harm caused in…
We are in favour of more demanding legislation regarding waste shipment. In the last years, Romania became the country of destination for plastic waste and rubber from used tires, from the European area. Almost 85,000 tons of tires enter Romania every year, from which only 25% are being recycled.
RREUSE is an international network representing social enterprises active in re-use, repair and recycling. RREUSE members currently divert around 1 million tonnes of goods and materials on an annual basis from landfill through re-use, repair and recycling.
· · filed 8 Apr 2020 · source
EDF welcomes the impact assessment carried out on the Waste Shipment Regulation (WSR) aimed at facilitating the re-use and recycling of waste within the EU. As a major actor in the energy transition, EDF has been committed for many years to the principle of circular economy when it comes to the preservation of natural resources - water, air, soil, raw materials - and waste management.
· · filed 8 Apr 2020 · source
As a responsible citizen of the world, and even more so as a promoter to circular economy, EU needs to stand firm on few principles: 1. all member states need to assume same ambitious recycling targets and elimination reduction targets; 2. there is no place for European refuse outside EU, as there is no place for non-European waste within EU; 3.
EUROFER welcomes the efforts of the EU Commission for making some EU laws instrumental in transforming the EU economy into a circular one and in reaching the goals of the EU Green Deal. The Waste Shipment Regulation (WSR) is one of them. It has been an effective instrument for improving environmental protection and regulating waste transport.
Public Affairs & Governmental Relations | Henkel EU Office Review of the EU Waste Shipment Background In its recently published Circular Economy Action Plan, the European Commission announces its plan to address waste exports from the EU.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Comments on the Waste Shipment Regulation Inception Impact Assessment by the Basel Action Network (BAN) Wednesday, April 8, 2020 BAN applauds the new emphasis found in the Circular Economy Action Plan -- one of the main blocks of the European Green Deal, calling inter alia for this "thorough review of EU rules on waste shipments.
EUCOPRO ASBL Rue Vilain XIIII, 53-55 Phone : [phone removed] Fax : [phone removed] EUCOPRO Interest Representative Identification number: 75111426376-95 8th April 2020 Waste shipments – Revision of EU rules Inception Impact Assessment EUCOPRO approaches EUCOPRO (European Association for Co-processing) is an association composed of waste pre-treatment companies that prepare alternative fuels and raw materials mainly…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EuRIC, the European Recycling Industries’ Confederation, strongly agrees with several issues arising from the Waste Shipment Regulation (WSR) that need to be tackled as indicated by the Impact Assessment. We, for instance, appreciate the emphasis put on the facts that the procedures are still mainly paper-based, there is no harmonization of interpretations of WSR provisions and procedures in different Member States…
EuroCommerce welcomes the opportunity to provide feedback regarding the Inception Impact Assessment on the revision of the Waste Shipment Regulation. The attached statement aims to summarize key points from the retail and wholesale sector on waste shipments and support the Commission’s work in revising the Waste Shipment Regulation.
We welcome the inception impact assessment (IIA) of the WSR stressing the intention to stop exporting waste outside the EU and revisit existing rules. The Circular economy set as a priority for the European Union is about designing waste out of the system. The increase of traded waste is certainly in contradiction with that objective.
Eurometaux, representing European manufacturers and recyclers of non-ferrous metals, supports efforts towards optimisation of the EU’s waste legislation, in order to secure level playing field for our high-quality recyclers and to remove barriers to intra-EU waste shipments.
The Austrian Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology as competent Austrian authority for waste management and transboundary waste shipment has drawn up the following opinion concerning the roadmap for the revision of the EC Waste Shipment Regulation: The BMK welcomes the proposed timetable or flow chart for the revision of the EC Waste Shipment Regulation.
The Federal Ministry of Climate Protection, the Environment, Energy, Mobility, Innovation and Technology (BMK), as the competent authority for waste management matters and cross-border shipments of waste, issues the following opinion on the roadmap for the revision of Regulation (EC) No 1013/2006 on shipments of waste: The BMK welcomes the proposed timetable or schedule for the revision of the EC Waste Shipment…
Filed in German · English published by the European Commission
Cerame-Unie, the European Ceramic Industry Association, welcomes the upcoming revision of the Waste Shipment Regulation as announced in the new Circular Economy Action Plan adopted by the European Commission on 11 March 2020.
· · filed 8 Apr 2020 · source
In general, the steel industry supports the European Commission’s efforts towards a European Green Deal and the planned measures to transform into a clean and circular economy. It is also acknowledged that waste management challenges must not be exported to third countries. However, this must not lead to a general ban on exports of waste, as it may make sense to treat waste in third countries.
Filed in German · English published by the European Commission
· · filed 8 Apr 2020 · source
The treatment of secondary raw materials and the definition of waste in circular economy legislation are among the pressing issues. Companies are concerned about the availability of recycled raw materials and the smooth cross-border transportation of the secondary raw materials. The message is clear: recycled raw materials should not be treated as waste as long as they don’t pose a health or safety threat.
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Neste Corp. (www.neste.com) is the world’s largest producer of renewable diesel refined from waste and residues, introducing renewable solutions also to the polymers and chemicals industries. Our business is focused on combating climate change and driving circular economy, and we are committed to becoming a solution provider in chemical recycling by providing cost-effective and sustainable innovations.
· · filed 8 Apr 2020 · source
Moving towards a Circular Europe AVR is a Waste Processing Energy Plant (WREP) based in Rotterdam (NL) with several other plants in the Netherlands. WREPs strive to retrieve maximal value from mixed household waste, commercial and industrial waste in a circular and environmentally sound manner.
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Our organization Polyeco S.A. has a long term experience (since 1990) regarding transboundary shipments of waste, within the EU and also to and from. As a result, based on the evaluation we have made all these years, and according to the Circular Economy aspects to be enforced, we consider that for sure transboundary movements of waste for recycling should be facilitated, but at the same time traceability control to…
VEOLIA is the global leader in optimised resource management. As a company carrying out waste management activities across Europe, Veolia is directly impacted by the Waste Shipment Regulation (WSR). The evaluation process is a timely initiative as a number of concerns deserve to be addressed in order to step up the implementation of the legislation and to respond to future european and international developments…
Based on the Commission's SWD evaluating the WSR and on the information provided through the IIA, HWE wants to share views on the Commission's understanding of the different problems pointed out. As a preliminary statement, we would like to insist on the fact that the WSR is an adequate piece of legislation at the EU level to ensure safe shipments of waste, traceability and to guarantee appropriate treatment of…
FERVER is the European federation of glass recyclers. It represents more than 40 members active in the recycling of both flat glass and container glass. These members operate in more than 80 sites in 20 European countries. They manage more than 70 % of the selectively collected container glass in Europe.
Filed in French · English published by the European Commission
European Recycling Platform (ERP) welcomes the European Commission’s plans to revise rules on waste shipment and to better align them with the overall objective of transitioning the continent towards a circular economy.
· · filed 8 Apr 2020 · source
ACEA welcomes the opportunity to provide comments to the European Commission Inception Impact Assessment on Waste shipments – revision of EU rules. ACEA believes that the Waste Shipment Regulation (WSR) does not effectively support the transition to a circular economy: the transboundary shipment of waste batteries aimed for recycling between EU Member States is currently subject to significant administrative…
CEWEP greatly appreciates the initiative’s objective to restrict “exports of waste that have harmful environmental and health impacts in third countries” as we believe that we should deal with our waste challenges here in Europe, where it is produced. In order to do that in an environmentally sound way, appropriate capacity for recycling and for residual waste treatment must be available in Europe.
Euroshore is the International association of companies active in ship waste management. Our mission is to contribute to the conservation of the oceans by leading the best practices in waste management for the maritime industry. Regulation 1013/2006 is a crucial working tool and business practice for Euroshore members within Europe, but also with third parties.
We need a revised WSR, which can promote circular economy within the EU by making transport across internal boarders easy for used goods destined for reselling with or without repair or reconstruction and waste destined for recycling. A number of proposals on how to do this is included in the enclosed file. Niels Bukholt on behalf of DI, the confederation of Danish Industry
EUROBAT very much welcomes the initiative to review the Waste Shipment Regulation. We believe that the Regulation needs to be better aligned to the principles of the circular economy, above all regarding the end-of-life management and recycling of spent batteries in low- and middle-income countries, which currently have sub-standard installations for these purposes.
The NABU welcomes the increased regulation of waste exports from the EU to non-EU countries. Not least through media reporting and NGO work, the devastating environmental and social consequences of waste exports to countries with low recovery infrastructure have become evident. Examples include exports of plastic waste to Asia and exports of waste electrical equipment to Africa.
Filed in German · English published by the European Commission
Cefic views on the revision of Waste Shipments Regulation Cefic has recently presented its 8-point Mid Century Vision for the Future of Europe; a Vision where the European Economy has gone circular, recycling all sorts of molecules into new materials.
The European Community Shipowners' Associations welcomes the opportunity to provide feedback on the revision of the EU regulation on waste shipments. ECSA wants to stress the importance of having a global regime in place for the recycling of ships, to create a global ship recycling industry that is circular and sustainable. The attachement gives more detail.
· · filed 7 Apr 2020 · source
ETRMA welcomes stricter rules for Waste Shipments Stricter rules for Waste Shipments is in line with a vision the tyre industry have been pioneering for decades and is also essential for the European new, Green Deal ‘no net emissions of greenhouse gases in 2050 and economic growth decoupled from resource use’.
The European plastics manufacturers support the intention of the Commission to review the current Regulation (EC) No 1013/2006 on shipments of waste (WSR), with a view to: - simplify and reduce burdens linked to its implementation; - ensure a smooth functioning of the EU internal market for waste destined for reuse or recycling, and support its transition to circular economy models; - better address illegal…
Provided on behalf of The Danish Chamber of Commerce and Mrs. Lisbet Hagelund: The Danish Chamber of Commerce supports the Commissions considerations, points and objectives in the Inception Impact Assessment regarding the revision of the Waste Shipment Directive. We believe it is necessary that the EU revises the WRS regulation in order to ensure a rapid shift towards a circular economy.
April 7, 2020 AFRA position on European Commission Roadmap on Waste Shipment Regulation The Aircraft Fleet Recycling Association (AFRA) is the leading organization worldwide for developing and promoting the safe and sustainable management of circularity of components and aircraft in the aviation sector.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 7 Apr 2020 · source
The Chemical Industry Federation of Finland (CIFF) believes that Europe should update its policy framework to create a well functioning single market for wastes in order to move from a waste-oriented to a resource-oriented European society. A full potential of the circular economy should be exploited.
Norway welcomes a revision of the Waste Shipment Regulation (WSR) and appreciates the opportunity to give feedback on the roadmap. Norway fully supports the initiative to improve the WSR relative to the ongoing Circular Economy Action Plan of the EU Commission. Increased use of waste as a secondary raw material is essential in the transition towards a circular economy.
Northvolt welcomes this initiative to review the Waste Shipment Regulation to better align with the EU Circular Economy Action Plan. The Battery industry is currently growing and Europe is currently in the middle of the upscaling of a complete new industrial value chain.
· · filed 7 Apr 2020 · source
European Precious Metals Federation (EPMF) welcomes EU Commission initiative on revision of the Waste Shipment Regulation (WSR) that plays a great role in new Circular Economy Action Plan. In order to move towards a more circular economy, EPMF suggests to reduce the administrative burden by switching to a harmonized electronic system and strongly supports fast track procedures for pre-consented facilities of waste…
CEMBUREAU, the European Cement Association (www.cembureau.eu), welcomes the Inception Impact Assessment and the opportunity to provide feedback to the Waste Shipment rules revision. The European cement industry is a large user of waste and by-products utilizing approximately 35 million tonnes per year.
DIGITALEUROPE fully subscribes to the initial objective of the WSR of protecting the environment from unsound waste management practices. DIGITALEUROPE believes there is a path to further increase the level of environmental protection by achieving more circularity for the EU. Today, the Circular Economy promotes the principle that waste is a resource, which should be re-introduced into the economy.
· · filed 7 Apr 2020 · source
We - the Hellenic Environmental Center (HEC) - believe that the revised Waste Shipment Regulation (WSR) should reflect changes across the following three pillars. 1. Harmonization of the notification process across all EU Member States in terms of : • The various documents needed when submitting the file; • The use of a common language.
The revision of the Waste Shipment Regulation provides the opportunity to address key issues that Plastics Recyclers Europe (PRE) is pleased to present. 1. Less administrative burdens, same environmental and human health protection To increase the circularity of plastic waste, transboundary shipments should become swifter and constraint by less administrative burdens.
The European aluminium industry supports the transition to a true circular economy, with realistic objectives and adequate measures. A well-functioning Waste Shipment Regulation is crucial to enabling Europe’s circular economy and ensuring the efficient use of raw materials.
· · filed 6 Apr 2020 · source
KIMO International welcomes this revision and agrees with the objectives laid out in the Inception Impact Assessment. The principles of this revision are common sense; the EU (nor any country) should be exporting waste internationally.
CEOE COMMENTS: “REVISION OF THE WASTE SHIPMENT REGULATION” 2 April 2020 Departamento de Industria, Energía y Medio Ambiente CEOE revision waste shipment 2 April 2020 INCEPTION IMPACT ASSESSMENT: Revision of the Waste Shipment Regulation (WSR) Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste BACKGROUND The European Commission has opened a public…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 6 Apr 2020 · source
ACE contribution to the consultation on the inception impact assessment: All the materials used in beverage cartons are recyclable. 49% of all beverage cartons sold in Europe were recycled in 2018. The recycling rate of beverage cartons will continue to increase thanks to the new EU waste legislation’s requirement to separately collect all packaging materials and the industry’s investments and the industry’s newly…
· · filed 31 Mar 2020 · source
Dear European Commission, Dear Lady/Sir, To: Frans Timmermans Executive Vice-President Subject: Environment - Agriculture for the Common Agricultural Policy after 2021. Topic: Notification and inquiry. We kindly ask the person receiving this electronic document to send our message below to Frans Timmermans Executive Vice-President. Sorry we use this interface to send notifications.
· · filed 30 Mar 2020 · source
ALPLA group agrees on the outcome of the evaluation to the WSR i.e. obstacles such as the current paper-based procedures and the lack of harmonization throughout the EU in terms of the waste transport within the EU. We also agree that illegal shipments of waste within the EU shall be controlled sufficiently in order to make illegal waste available to the market.
Plastic Change Islands Brygge 39 2300 København S Denmark Ref. Ares(2020)1905283 - 02/04/2020 Feedback på initiativet “Waste shipments – revision of EU rules” Plastic Change er positivt indstillet overfor, at I har evalueret den europæiske affaldseksport regulering (WSR), og ser frem til at følge den videre proces.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
· · filed 25 Mar 2020 · source
EERA, the European Electronics recyclers Association endorses the paper the EC just published “Inception impact assessment” as introduction paper into the review of the Waste Shipment Regulation in the course of this year. We would like to emphasize that the EC addresses the right themes in this paper and that we believe that our project to simplify and harmonize notifications in Europe fits in well with this.
· · filed 22 Mar 2020 · source
Specifically, the European Union must ensure that containers where the polluting materials or residues are shipped comply with international standards, from the type of containers, materials, type of transport, storage.
Filed in Spanish · English published by the European Commission
· · filed 20 Mar 2020 · source
We welcome this initiative of revision of the Waste Shipment Regulation (WSR) to align better with the new Circular Economy Action Plan and the European Green Deal in general. We would like to highlight the importance of having a strong and encompassing WSR for the ocean and the European seas.
Many low- and middle-income countries do not have the capacity to safely process waste, especially e-waste and waste containing used lead acid batteries (ULABs; other batteries). As pointed out, unsafe recycling and waste processing, especially improper substandard ULAB recycling, has detrimental impacts on the health and environmental, disproportionately impacting children, women, the poor and vulnerable…
In view of saving ressource through a circular economy the handling of easy to collect and unmixed thermoplastics need to be reviewed. The HS Code for unmixed thermoplastic that can be reprocessed needs to reflect that it is not waste but a raw non-virgin material if it is being sent to Non-EU countries for reprocessing. I addition used electrical equipment defined under WEEE that can be remanufactured (e.g.
We as EGARA feel that for correspondents guideline no 9, involving transboundary transport of vehicles, easier rules for distinguishing cars (products) from ELV's (waste) need to be added. Sometimes it's hard to decide if something is a car or an ELV. Several methods exist. One is not necessarily better than another, it depends on the specific case. Also a hierarchy in methods can be a solution.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.