Waste Framework Directive: textiles and food waste

Zero Waste Alliance Ireland (ZWAI) is very pleased to have the opportunity to provide additional feedback to the European Commission at this stage, when the Commission is considering the adoption of a revised targeted Waste Framework Directive, to be presented to the European Parliament and Council.

Thank you for the opportunity to comment on this important directive. Fibershed works with a global network of over 60 Affiliate communities (fiber and textile producers, processors, manufacturers, designers and wearers) dedicated to building regionally-based natural fiber textile systems that improve ecosystem and community health, cultivating new models for textile economies and culture.

The current revision of the Waste Framework Directive, which has guided EU policy in this area since 1975, offers an opportunity to design a coherent and consistent policy framework for a circular economy. Unlocking this potential requires a policy landscape that will create the opportunities, incentives, and confidence necessary for businesses to innovate and invest in the new business models that will break the…

Oslo (Norway), 22. November 2023 Priorities for the Waste Framework Directive (WFD) Revision proposal 2023/0234(COD) Future in our hands, Norway appreciates the opportunity to contribute to the discussion on the proposed revision of the Waste Framework Directive. For our organization priorities, this document will focus mainly on the proposed extended producer responsibility (EPR) for textiles.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

H&M Group welcomes the proposed revision of the Waste Framework Directive (WFD) which aims to establish a harmonised Extended Producer Responsibility (EPR) for textiles and footwear across EU Member States. We advocate for unified EPR rules to drive a shift towards a more circular operating model in the fashion and textile industry.

The current model of generation and waste management in Poland and other EU countries is highly unsustainable. Phenomena such as huge amounts of food waste and millions of tonnes of unprocessed textile waste, and consequently the economic, social and environmental costs of inefficient and often unfair distribution of products and resource management, are largely due to the lack of adequate legislation, social and…

Filed in Polish · English published by the European Commission

Veterinarians are committed to sustainable food systems by assisting and supporting farmers in preventing and reducing food losses and food waste (FVE position paper- Veterinarians commit to sustainable food systems - https://rb.gy/e6d9iq) Veterinarians of Europe are well aware of the 59 million tonnes of food waste (131 kg per inhabitant) generated annually with a market value of around 132 billion euros.

SHV Energy is a leading global distributor of off-grid energy such as LPG and LNG and is active in the area of sustainable fuels (bioLPG, bioLNG, rDME) and renewable energy solutions (energy efficiency, solar). SHV Energy is a wholly owned subsidiary of SHV, a family-owned multinational, and consists of a group of specialised energy companies.

Avery Dennison is a global materials science and digital identification solutions company that provides branding and information labelling solutions, including pressure-sensitive labels, RFID inlays and tags aimed at connecting the physical with the digital.

Stellungnahme zum Vorschlag zur Novellierung der Abfallrahmenrichtlinie 2008/98/EC November 2023 Vorbemerkung Der BVMed vertritt als Wirtschaftsverband über 300 Industrie- und Handelsunternehmen der Medizintechnik-Branche. Im BVMed sind neben Herstellern und Zulieferern der MedTech-Branche ebenfalls Hilfsmittel-Leistungserbringer und HomecareVersorger organisiert.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

DM&T welcomes the proposal for a targeted revision of the Waste Framework Directive (WFD) and the EU regulatory efforts to solve the textile waste problem, both to reduce waste and to enable textile waste recycling. The 2025 mandatory separate textile waste collection in the EU requires coordination and investments to build a European textile recycling value chain which could recycle 2.2 min tons by 2030.

1 November 22nd, Madrid Repsol’s feedback on the revision of the Waste Framework Directive (WFD) Repsol welcomes the opportunity to provide feedback on the European Commission's initiative to review the Waste Framework Directive (WFD), which aims to better implement and strengthen the EU waste hierarchy to optimize waste prevention, preparation for re-use and recycling.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Matter welcomes the revised Waste Framework Directive and hopes to see further detail arising though adoption and implementation. In particular, we are excited to understand the potential for measures to address micro-pollutant waste, including from microplastics and microfibres.

ACR+ is an international network of cities and regions sharing the aim of promoting a sustainable resource management and accelerating the transition towards a circular economy. For 30 years we have guided public authorities in the development of their expertise and skills in effective waste-product-resource policies and encouraged them in their practical action.

LUnion of Textile Industries welcomes the proposed revision of the Waste Framework Directive and the EU’s regulatory efforts to address the problem of textile waste, both to reduce waste and to enable the recycling of textile waste.

Filed in French · English published by the European Commission

FIPRA is submitting this input on behalf of the Smart Food Technologies (SFT) Coalition. The Coalition for Smart Food Technologies is an initiative founded in September 2023 and sponsored by HelloFresh, Keep-It Technologies, and Zebra Technologies.

FEAD is fully committed to the objectives of the European Green Deal and the Circular Economy Action Plan as essential tools for providing the adequate stimuli to our economy while pushing forward EU Climate goals through the circular economy.

EuroCommerce is the principal European organisation representing retailers and wholesalers. Our members include national associations in 27 countries, leading European companies and circa 5 million SMEs. Our sector generates 26 million jobs.

Tetra Pak, global leader in liquid food processing and packaging solutions, is committed to supporting and enabling food systems transformation through technologies and collaborations that help reduce the climate impact of food production.

We believe that the EU Waste Framework Directive is a one of the most important legislations that should support the transition to the circular economy, moving away as much as possible from waste management to resource efficiency. We feel a critical opportunity has been missed in addressing the fundamental issue of the definition of waste in the proposed revision of the Waste Framework Directive (WFD).

EURATEX appreciates the opportunity to provide feedback on the Waste Framework Directive revision proposal. EURATEX welcomes the proposal for a targeted revision of the WFD and the EU regulatory efforts to solve the textile waste problem, both to reduce waste and to enable textile waste recycling.

Enerkem and Dimeta welcome the opportunity to share its views on the revision of the Waste Framework Directive (WFD). The proposed revision primarily focuses on textile and food waste and aims to reduce waste generation while improving preparation for re-use or recycling.

CEN and CENELEC welcomes the revision of the Waste Framework Directive (WFD). The extension of the scope of the framework to textiles and food waste is a great step in strengthening the European circular economy. European Standards can play a vital role in providing the technical guidance needed to make the necessary practical changes to implement the ambitions laid out in this proposal.

The BGA supports the Commission’s proposal to set food waste reduction targets for Member States by 2030 as part of the revision of the Waste Framework Directive. If properly and proportionately set, these targets can accelerate the reduction of food waste along the food supply chain, while supporting the EU’s efforts to achieve Sustainable Development Goal 12.3 (SDG 12.3).

Filed in German · English published by the European Commission

The WFD requires an update, especially to align EU legislation with EU policy objectives to promote circularity in the textile industry and to take advantage of the role that Extended Producer Responsibility (EPR) schemes can play for this purpose.

Filed in Spanish · English published by the European Commission

‭ ow‬‭to‬ ‭Ensure‬‭Waste‬ ‭Colonialism‬‭is‬‭Not‬‭Written‬‭Into‬‭Law‬‭and‬ H ‭That Fashion’s Biggest Polluters Have to Change‬ ‭ nalysis and Suggested Changes for The European Commission’s Proposed Waste Directive‬ A ‭Amendment‬ ‭The‬‭European‬‭Commission’s‬‭proposed‬‭amendments‬‭to‬‭the‬‭Waste‬‭Directive‬‭exhibit‬‭the‬‭clear‬‭ambition‬ ‭…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

GO!PHA is a non-profit engaged in promoting circular and sustainable materials such as PolyHydroxyAlkanoate (PHA) biopolymers that are renewable, biodegradable and compostable. We welcome the Commissions proposal to revise the Directive on waste.

The Swedish Shoe Environmental Initiative (SSEI) is an environmental network for the Swedish shoe industry with 27 member companies (www.ssei.se). Our members include both large companies as well as smaller companies in the shoe industry. We are happy that we have had the opportunity to comment on the revision of the Waste Directive.

Directiva Marco de Residuos: textil alimentación Ref. Ares(2023)7964460 - 22/11/2023 21 de noviembre de 2023 Comentarios de CEOE sobre la propuesta de Revisión de la Directiva marco sobre residuos: sector textil y alimentario. ANTECEDENTES La Comisión Europea (CE) ha abierto una consulta pública para la modificación de la Directiva marco de Residuos (DMR) centrada en los sectores alimentario y textil.

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Footwear Confederation (CEC) welcomes the proposal on the revision of the Directive 2008/98/EC on waste (also know as Waste Framework Directive - WFD) tackling i.a. textiles and textiles waste and thanks the European Commission for the opportunity to provide feedback.

The Nature and Biodiversity Conservation Union (NABU) welcomes the Commission's proposal for a revision of the Waste Framework Directive. However, we regret the lack of ambition regarding the volume reduction of the targeted waste streams and would like to point out that the proposed targets for food waste reduction are too low.

The Tessile, Abbiamento, Moda del GdL4 (Sustainable and Circular Value Chains) of the Italian Circular Economy Actors Platform (ICESP – TAM) has developed, in a cooperative manner, a document proposing and presenting comments and amendments to the proposal for a Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste.

Filed in Italian · English published by the European Commission

The European Commission's introduction of a framework for the reduction of food waste and an extended producer responsibility scheme for textiles is strongly supported. When revising the Waste Framework Directive, the European Commission could rely on Austria's experience in the management of waste textiles and the reduction of food waste.

Erion Textiles is the Italian EPR scheme for textiles, representing important Producers: Miroglio Fashion, Amazon, Artsana, Save The Duck, Essenza and Rimoda Lab. We analysed the revision of the WFD and the following comments represents the observations of our Producers and discussed with relevant stakeholders in Italy and in Europe.

Norwegian Environment Agency welcomes the opportunity to provide feedback on the Proposal for a Directive, amending Directive 2008/98/EC on waste. Please find attached our comments. Our key input is: Regarding food waste: o Member states should have the possibility to use an earlier reference year than 2020, in case they have started targeted national work to cut food waste prior to this year.

VF Corporation Feedback on the revision of the Waste Framework Directive VF outfits consumers around the world through its diverse portfolio of iconic lifestyle brands, including the Timberland ®, Vans ® and The North Face ®. At VF, we power movements of sustainable and active lifestyles for the betterment of people and the planet.

Please find attached the BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (Federation of the German Waste, Water and Circular Economy Management Industry)'s detailed feedback on the Revision of the Waste Framework Directive.

The Federation of the European Sporting Goods Industry (FESI) and its members welcome the publication of the European Commission proposal for the targeted revision of the Waste Framework Directive. Overall, we believe that the proposal represents a good attempt at providing legal certainty for economic operators placing products on the internal market and at supporting the investment in the fibre-to-fibre recycling…

Berlin, 22. November 2023 Deutsche Industrie- und Handelskammer DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2008/98/EC on waste Europäische Kommission vom 05. Juli 2023 Grundlage dieser Stellungnahme sind die der DIHK bis zur Abgabe der Stellungnahme zugegangenen Äußerungen der IHKs sowie die wirtschaftspolitischen/europapolitischen Positionen (und ggf.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Commissions proposal to revise the Waste Framework Directive (WFD) rightly aims at reducing food waste as well as better managing textile waste in a more circular and sustainable manner. The proposal is a welcome step towards establishing circularity for textiles by including mandatory extended producer responsibility (EPR) for textiles, incentives for the development and uptake of fibre-to-fibre…

DANSK ERHVERV Ref. Ares(2023)7958649 - 22/11/2023 November 22, 2023 Consultation on the revision of the Waste Framework Directive The Danish Chamber of Commerce has received a consultation on the revision of the Waste Framework Directive focusing on food waste and extended producer responsibility on textiles and has the following comments.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Lenzing Aktiengesellschaft [address removed], Austria www.lenzing.com Date: November 22, 2023 Contact Dr. Danijela Cafuta Phone [phone removed] Lenzing Group’s contribution: E-mail [email removed] Environmental impact of waste management – revision of EU waste framework Date January 18, 2023 Lenzing Group, founded and headquartered in Austria, is a € 2.56 billion (2022) world leader in ecologically responsible…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

CIA Agricoltori Italiani, one of the main agricultural organisations in Europe presenting Italian farmers and agricultural business owners, satisfying the unity to provide feedback on the Proposal for a Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste. Please find attached Cia Agricoltori Italiani feedback.

Filed in Italian · English published by the European Commission

Position of the bvse e.V. on the European Commission's proposal for a Directive amending Directive 2008/98/EC on waste COM (2023) 420 final We hereby comment on the European Commission's proposal for a directive amending Directive 2008/98/EC on waste, hereinafter referred to as the Waste Framework Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Decathlon welcomes the revision of the Waste Framework Directive (WFD), and in particular, we strongly support the establishment of Extended Producer Responsibility (EPR) schemes for textiles and footwear, in line with the EU Strategy for Sustainable and Circular Textiles. Decathlon has more than 10 years of experience with textile EPR schemes, notably in France with ReFashion and SCRAP in Spain.

The European steel sector welcomes the forthcoming revision of the EU Waste Framework Directive 2008/98/EG (WasteFD) intending to reduce the environmental and climate impacts, increase environment quality and improve public health associated with textiles and food waste, and contribute to the ambition of the European Green Deal in terms of reducing waste generation and the transition to a circular economy.

Návrh směrnice Evropského parlamentu a Rady, kterou se mění směrnice 2008/98/ES o odpadech – připomínky Hospodářské komory ČR Hospodářská komora ČR (HK ČR) vítá možnost vyjádřit se k návrhu směrnice, kterou se mění směrnice 2008/98/ES o odpadech. Níže uvádíme připomínky našich členů. KONKRÉTNÍ PŘIPOMÍNKY Článek 9a Předcházení vzniku potravinového odpadu, odst.

Filed in Czech · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ACE The Alliance for Beverage Cartons and the Environment provides a European platform for beverage carton manufacturers and their paperboard suppliers to benchmark and profile beverage cartons as a safe, circular and sustainable packaging solution with low carbon benefits. Thanks to their composition, beverage cartons allow to safely pack, transport, shelve and use sensitive products such as milk and juice.

UECBV supports the Commission's efforts to reduce food waste in the European Union and is dedicated to helping reach the targets proposed, thereby mitigating the climate impact and lowering emissions. Our members have undertaken multiple initiatives to decrease the food waste in the meat sector and show daily commitment to the goals proposed with initiatives targeting food companies and stakeholders in the food…

Finnish Textile and Fashion is the central organisation for textile, clothing and fashion companies in Finland. We promote the Finnish textile and fashion industry and our member companies globally. We have over 250 member companies in the textiles and apparel industry.

Filed in Finnish · English published by the European Commission

Stellungnahme Überarbeitung der EU-Abfallrahmenrichtlinie Konsultationsbeitrag der Arbeitsgemeinschaft der deutschen Lebensmittelhandwerke (AGLMHW) Brüssel, 22.11.2023 Zentralverband des Deutschen Handwerks Abteilung Europapolitik Ansprechpartnerin: [name removed] [phone removed] [email removed] Lobbyregister: R002265 EU Transparency Register: 5189667783-94 Einleitung: Der am 5.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Statement on the Draft of the EU Commission on the Waste Framework Directive – particularly on "Extended Producer Responsibility" Preface As part of the EU Textile Strategy, the EU plans to introduce a binding and harmonized system of "Extended Producer Responsibility" (EPR) in all member states.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The (WFD) could improve the environmental performance of fashion and textile industries, but should focus on waste prevention reducing overproduction and disposable fashion. Measure the real life of clothes not by unreliable parameters on durability measured through mechanical strength or weight, but real use data on garments retention and use, enforcing labels for date of manufacturing, disposed garments audits.

Refashion, the French PRO for Textile, household Linen and footwear, welcome the proposed revision of the Waste Framework Directive, which is a step in the right direction towards rising circularity within the textile and footwear sector. In particular, Refashion supports the introduction of harmonised Extended Producer Responsibility (EPR) systems in all EU member states.

Filed in French · English published by the European Commission

Views of Turkish Apparel Industry on Waste Framework Directive (WFD) Proposal About IHKIB and Turkish Apparel Industry: Istanbul Apparel Exporters Association (IHKIB) is the leading exporting association in Türkiye, with a representative power of more than 70% of Turkish apparel exporters with its more than 20 thousand of apparel exporting company members.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Essity is a leading global hygiene and health company with sales in approximately 150 countries and about 48,000 employees (about 1/3 in the EU). Essity breaks barriers to well-being and contributes to a healthy, sustainable, and circular society.

We welcome the possibility to provide feedback to this consultation. At the European Parliament level, we noticed some push from different political groups to include primary production. This said, and if option 3 will be chosen, Animal Health can be one of the most important allies to achieve the legally binding target of 10% for the primary production.

EuroCommerce, representing European retailers and wholesalers, welcomes the opportunity to provide feedback regarding the proposal to revise textile-related aspects of the Waste Framework Directive. Retailers and wholesalers experience differences and diverging implementation, especially in Extended Producer Responsibility (EPR) requirements in the Member States.

The Federal Association of the German Confectionery Industrie e.V. would like to comment as follows on the European Commission’s proposal to revise the EU Waste Framework Directive 2008/98/EC with regard to food losses: In principle, the following applies to food production: Due to the high cost of food and its raw materials, producers have a vested interest in minimising food losses. 1.

Filed in German · English published by the European Commission

The International Confederation of Paper & Board Converters (CITPA) and its member associations support the intention of the European Commissions revision of the Waste Framework Directive (WFD) to reduce waste production. This legislative update is especially critical given the environmental, economic and societal impacts of food waste.

The European Federation of Corrugated Board Manufacturers (FEFCO) supports the intention of the European Commissions revision of the Waste Framework Directive (WFD) to reduce waste production. This legislative update is especially critical given the environmental, economic and societal impacts of food waste. FEFCOs key recommendations for the revision are: 1.

Proposal on food waste reduction targets as part of the revision of the Waste Framework Directive Confcommercio’s feedback 21 November 2023 Confcommercio welcomes the opportunity to provide feedback on the proposed amendment to the Waste Framework Directive, specifically concerning aspects related to food and food waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Feedback to the Proposal of the European Parliament and the Council to Amend Directive 2008/98 on Waste 1. Promoting the Role of Packaging in Food Waste Avoidance Sealed Air calls for a more formal and visible recognition of the essential role of food packaging in preventing food waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ETSA, or the European Textile Service Association, is a key organization in the textile services sector. It offers services like cleaning and renting out reusable textiles such as work clothes, linens, and uniforms. ETSA is also involved with textile producers, national associations, machinery, and cleaning products. Since 2021, it has been working as an Ambassador for the European Commission Climate Pact.

SUEZ welcomes the European Commissions proposal on the revision of the Waste Framework Directive regarding food waste. In this position paper SUEZ wants to highlight some remarks on the proposed legislation in relation to the proposals regarding food waste.

ENSIE fully endorses RREUSE's Feedback to the 2023 Targeted Revision of the Waste Framework Directive. ENSIE welcomes the current discussions around the revision of the Waste Framework Directive (WFD) as it is a key opportunity to ensure consistent application of the waste hierarchy throughout the EU, it is also an opportunity to develop synergies between the social and circular economy objectives by supporting…

Amazon supports a review of the WFD that includes and contributes to: 1. Harmonizing and simplifying the Extended Producer Responsibility (EPR) process by: (i) Proposing an EPR one-stop-shop, a centralized information portal providing the latest up to date information of different EPR requirements across all the European Member States, both at a national and product-specific level; (ii) Promoting a Pay-On-Behalf…

Please find enclosed our feedback on the revision of EUs Waste Framework Directive. We commend the EUs efforts to revise the Waste Framework Directive and to provide a clearer framework for social enterprises in an improved economy for collecting, sorting, and handling of textiles and waste textiles.

TEKO, the Swedish trade and employers association for the textile and fashion industry, appreciates the opportunity to contribute to the discussion on the proposed revision of the Waste Framework Directive. As advocates for sustainable practices in the textile industry, TEKO shares its insights on key aspects of the directive. TEKO supports the Commission's initiative to revise the Waste Framework Directive.

Fibre Packaging Europe (FPE) is an informal coalition of seven trade associations along the fibre packaging value chain in Europe. Coming together to speak with one voice on the policy issues central to our ecosystem, collectively, FPE members represent 1500 companies employing 365,000 people across 2,200 facilities in Europe, generating around 120 billion in annual turnover.

PLEASE REFER TO THE ATTACHED DOCUMENT TO ACCESS THE COMPLETE FEEDBACK RREUSE supports the proposed revision of the Waste Framework Directive, recognizing its significance in acknowledging the pivotal role of social enterprises in promoting textile re-use.

Independent Retail Europe would favour an approach whereby Member States would have flexibility to set their own sector-specific targets, proportionate to the contribution each sector makes to food waste and invites the EU institutions to consider the following aspects: Food chain operators can only be responsible for waste that is under their control.

Compassion in World Farming Brussels (CIWF EU) welcomes the ongoing efforts to curb food waste in the bloc and the opportunity to contribute to this public consultation. As the proposal highlights, the agri-food system is a most resource-intensive sector, it is crucial that inputs with higher environmental footprint are treated with the necessary care and their loss and waste are cut to the barest minimum, if not…

MOL Group’s position on the Commission proposal for a revised Waste Framework Directive MOL Group is committed to helping the EU in reaching its circular economy objectives and is transforming to adapt to a circular and low-carbon world.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

21.11.2023 Zero Waste Europe’s feedback to the proposal for a targeted revision of the Waste Framework Directive (2023/0234 (COD)) Contents Contents.................................................................................................................................................................................................................1 Strengthen the provisions on food waste and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Environmental Bureau (EEB) welcomes the Commission's proposal to revise the Waste Framework Directive but regrets the limited scope of the revision. In our attached position paper we detail the following recommendations to policymakers.

Vantaa Energy views the Commissions proposal for a revision of the Waste Framework Directive as a positive step towards reaching the EUs ambitious 2040 targets. However, the current revision is not sufficient for delivering the more fundamental changes needed in the Waste Framework Directive.

Feedback from TESS GEIE: - Short version below - Attached: detailed version - Attached: Legal analysis. What is the value of the act of handing over used textiles (donation vs. act of discarding)? What is the qualification of these textiles (products vs. waste)? (French and translation in English) NB: both annexes are merged in a same PDF document.

Inditex’s contribution: “Public Consultation: Revision of the Waste Framework Directive” Inditex welcomes the targeted revision of the EU’s Waste Framework Directive (WFD). The WFD requires updating, particularly to align EU legislation with the Union’s policy objectives to promote circularity in the textiles industry and leverage the role that Extended Producer Responsibility (EPR) schemes can play to that end.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

the European Safety Federation wants to express some concerns about the current proposal. Some proposed amendments in the EU Parliament already respond partially to our concerns. More clarification on the scope (only consumer products are also technical / professional products ? The CN codes in the annex are not suitable to define the scope as the range of products covered by the CN codes is too wide.

The Verband der Fleischwirtschaft e.V. (VDF) rejects the plan to set a quantitative target for the reduction of food waste on the following grounds: Food waste means economic losses for food business operators. Each operator shall aim to maximise the use of his products. In addition, it is precisely in the meat sector that disposal costs are high.

Filed in German · English published by the European Commission

REMARK SLU ID: SLU.ua.2023.2.6-3466 2023-11-22 EU have your say Remarks on proposal for the directive regarding food waste: Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive 2008/98/EC on waste Summary The Swedish University of Agricultural Sciences (SLU) supports the EU commission’s initiative regarding the proposal for legally binding EU targets to reduce food waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Policy Hub Circularity for Apparel and Footwear, uniting more than 700 brands, retailers, manufacturers, and other stakeholders within the industry and representing more than 50% of the apparel and footwear sector welcomes the Commission's efforts to revise the Waste Framework Directive (WFD).

November 20th, 2023 Position Paper on the Waste Framework Directive revision – Enerkem’s comments on the proposal for a Directive – Enerkem welcomes the opportunity to share its views on the revision of the Waste Framework Directive (WFD). The proposed revision primarily focuses on textile and food waste and aims to reduce waste generation while improving preparation for re-use or recycling.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

MIWA welcomes the European Commissions proposal to revise the Waste Framework Directive (WFD), particularly its focus on food waste. MIWA encourages the Commissions efforts to complement the PPWR with other legislation targeting waste to allow for a more efficient overall outcome.

The International Flight Services Association (IFSA) welcomes the European Commissions proposal for the ‎revision of food waste and textile aspects of the Waste Framework Directive and the aspiration to achieve the ‎United Nations Sustainable Development Goal (UN SDG) target to halve food waste by 2030. IFSA is committed ‎to helping reduce food loss and waste.

Resortecs supports the modernization of the waste management framework in the textiles industry, vital to make circularity and innovation the norm. This is an important step towards realizing the European Commissions 2030 vision for a competitive, resilient and innovative textiles sector, particularly so that all textile products placed on the EU market are ecodesigned, sustainable and with producers taking…

Deutsche Umwelthilfe e.V. (DUH) welcomes that the Commission proposes to amend the Waste Frame-work Directive (WFD) and appreciates the opportunity to provide feedback on the proposal. Since DUH has been working intensively on food waste for years, we will focus on aspects related to food waste.

Dear ladies and gentlemen, we welcome the opportunity to provide feedback on the planned amendment of the Waste Framework Directive. Coherence and harmonisation in the measurement methodology, with maximum flexibility for Member States otherwise, and reduction targets based on the proportion of losses at the various stages of the food recovery chain are the right way to tackle food waste in a sustainable and…

Filed in German · English published by the European Commission

We, the forum for reduced food waste in Sweden (a k a Matsvinnet.se), are grateful for the initiative to launch legally binding EU food waste targets. However, we strongly advocate for the most ambitious option, Option 3, which is: Target for primary production 10%, Target for processing and manufacturing 25%, Target for retail and consumption stages 50%.

This contribution aims at providing feedback on behalf of I.BLU (IREN Group) to the Commission Proposal for a Directive of the European Parliament and of the Council amending directive 2008/98/EC on waste. The revision of this file is welcome and necessary, especially with regard to the aim of reducing the environmental and climate impacts associated with the textile waste and the generation of food waste.

Summary of Ragn-Sells view on the Commissions proposed revision of directive 2008/98/EC on waste Transitioning to a circular economy is crucial to our ability to mitigate climate change, the depletion of our natural resources, and the risk of overshooting planetary boundaries.

WWF Germany welcomes the European Commissions proposal for EU-wide legally binding food waste reduction targets.The setting of binding targets is a much-needed step to stimulate action by Member States and food businesses across the value chain.

Fipe is the most representative Association of the Confcommercio system and leader in the catering, entertainment, and tourism sector, in which over 335 thousand companies operate with almost one million employees who generate an added value of approximately 43.5 billion.

Please find attached Fortum's feedback to the consultation on the Environmental impact of waste management - revision of EU waste framework. The same information can also be found here: https://www.fortum.com/about-us/public-affairs/our-views-and-positions

Recommendations 1.Set performance targets that respect the waste hierarchy and support closed-loop recycling instead of downcycling (e.g. polyester from recycled plastic bottles). Commissions proposal lacks prevention, collection, reuse and recycling targets, potentially compromising the waste hierarchy and undermining the impact of fibre-to-fibre recycling technologies.

essenscia position addresses three issues: 1. material neutral approach 2. the proper use of the legal instrument of Extended Producer Responsibility which cannot legally include recycled content as modulation as EPR is about the management and the valuation of waste, not about the product placed on the market 3.

VCI-POSITION Comments on the Proposal (COM(2023)420) for a Directive of the European Parliament and oft the Council amending the EU Waste Framework Directive (2008/98/EC) of 5.7.2023 With this draft, the EU Commission intends to revise the EU Waste Framework Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

14 October 2023 The European members and associates of Humana People to People reaction to the Proposal for a targeted revision of the Waste Framework Directive (COM 2023 420 final, 5.7.2023) As specialists in textile resource management, the European members and associates of Humana People to People are fully committed to promoting and furthering a more sustainable and circular use of textile, textiles-related and…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FNADE, the French association for recycling and waste management fully supports any initiative that aims both to reduce waste production (in particular through prevention) and to promote recycling and circular economy. Nevertheless, we would like to take the opportunity to make some comments on the Waste Framework Directive revisions proposal.

Gemeinschaft für textile Zukunft, GftZ welcomes in general the approaches of the European Commission to amend the Waste Framework Directive with regard to the handling of textiles. From the GftZ's point of view, the implementation of extended producer responsibility is the key to transforming the textile market into a high-quality circular economy.

The European Branded Clothing Alliance (EBCA) welcomes the European Commissions proposal for a targeted revision of the Waste Framework Directive (WFD). EBCA recognizes that a targeted revision of the Waste Framework Directive can improve the environmental impact of the textiles industry and deliver concrete advantages for both the industry and the planet.

9 October EBCA’s position on the targeted revision of the Waste Framework Directive The European Branded Clothing Alliance (EBCA) welcomes the European Commission’s proposal for a targeted revision of the Waste Framework Directive (WFD).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In the light of the above, we acknowledge that the Commission intends to finalise the revision of the Waste Framework Directive as soon as possible, through enhanced and accelerated action by the EU and the Member States to ensure the environmental sustainability of the food sector, in line with the Green Deal and Sustainable Development Goal (SDG) 12.3 to halve global food waste by 2030.

Filed in Italian · English published by the European Commission

ECMA & Pro Carton are delighted to provide the attached feedback to the revision of the EU waste framework We bring together folding carton converters, cartonboard mills, national associations and suppliers to the folding carton industry.

Finnish Biocycle and Biogas Association welcomes the Comission Proposal for a targeted revision of the Waste Framework. The Finnish Biocycle and Biogas is a national Association interested in nutrient recycling and biogas promotion and correspond the production of recycled fertilizers. With this paper, we would like to take a position on the proposed amendment to the directive on food waste.

By revising the Waste Directive, the Commission aims to reduce waste by identifying specific recovery targets at the various stages of the chain and requiring Member States to implement appropriate measures to reduce waste generation.

Filed in Italian · English published by the European Commission

The Wasted Textiles policy consortium (The Consortium) welcomes the dedicated attention of the European Commission on minimizing the environmental impacts of textiles and the previously published comprehensive Waste Framework Directive revision proposal.

The European Compost Network ECN welcomes the opportunity to provide feedback on the Commissions public consultation concerning the new proposal for a revised waste framework directive (WFD), focusing on food and textiles aspect. Food waste is an important fraction of bio-waste and its generation its mismanagement must be addressed properly.

Svenskt Näringslivs position om EU-kommissionens förslag på revidering av avfallsdirektivet (2008/98/EG) Svenskt Näringsliv företräder drygt 60 000 små, medelstora och stora företag. Dessa är organiserade i 49 bransch- och arbetsgivarförbund. Förbunden utgör föreningen Svenskt Näringslivs medlemmar. Svenskt Näringslivs ställningstagande har utarbetats efter samråd med berörda branschförbund inom Svenskt Näringsliv.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Danish Agriculture & Food Council (DAFC) supports the Commission's focus on food waste and aims for a reduction in quantities at the EU level. This is necessary to meet the ambitions of the UN Sustainable Development Goal 12.3, which aims for a 50% reduction in food waste in households, retail, and food service sectors, as well as reduction throughout the rest of the chain.

DATUM BETECKNING 2023-11-01 Remissyttrande Yttrande över EU-kommissionens förslag till revidering av avfallsdirektivet Södra skogsägarna har beretts möjlighet att yttra sig över EU-kommissionens förslag till revidering av avfallsdirektivet. Södras Skogsägarna är Sveriges största skogsägarförening med 52 000 medlemmar som sammanlagt förfogar över 2,8 miljoner hektar skog.

Filed in Swedish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Warszawa, 30 października 2023 r. Szanowni Przedstawiciele, Szanowne Przedstawicielki Komisji Europejskiej, W imieniu Green REV Institute chcemy podziękować za możliwość zajęcia stanowiska w ramach konsultacji: Cele w zakresie ograniczenia marnowania żywności. Zrównoważony System Żywnościowy UE Marnowanie żywności jest jednym z elementów i konsekwencji nieefektywnego systemu produkcji żywności.

Filed in Polish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Sustainable Business Federation - Ecopreneur.eu and its membership of sustainable frontrunners welcome the European Commissions initiative of a revised Waste Framework Directive (WFD) to reduce waste.

Position paper FIPE - EU proposal for Food Waste Reduction Targets (Proposal for a Directive of the EU Parliament and of the Council amending Directive 2008/98/EC on waste) Fipe is the most representative Association of the Confcommercio system and leader in the catering, entertainment, and tourism sector, in which over 335 thousand companies operate with almost one million employees who generate an added value of…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Landowners Organization (ELO) welcomes the opportunity to provide feedback on the recently published Proposal for a Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste.

Cepi welcomes the revision of food waste and textile aspects of the EU Waste Framework Directive. In this response, we will focus on these aspects. However, Cepi deplores the limited scope of the revision and would like to comment on crucial issues such as the increased efficiency of waste management systems, higher quality secondary raw materials through separate collection and high-quality recycling that have not…

Plastics Recyclers Europe welcomes the ECs initiative to revise the Waste Framework Directive (WFD), as an opportunity to improve the waste management of the textile sector, in line with the EU waste hierarchy and the objectives of the EU Textiles Strategy. Please find attached our feedback on the proposal.

We welcome the revision of the EU Waste Framework Directive and all efforts to inform and improve delivery of the EUs environmental strategies in the fashion and textile industry. The WFD's intentions are commendable; however, the revisions focus on waste prevention is too narrow, missing significant opportunities to inform and improve the delivery of a suite of EU environmental strategies in the fashion and textile…

Visita welcomes the proposals binding reduction targets specifically targeted towards parts of the hospitality sector, namely the generation of food waste per capita in total within retail and other food distribution, restaurants, food services and households with 30% by 2030 compared to 2020.

The Waste Framework Directive is a critical legislative instrument guiding waste management operators across EU Member States. As the EU seeks to continually enhance its environmental policies, the European Recycling Industries Confederation (EuRIC) commends the efforts to partially revise this Directive to address current challenges.

A2A Group, the Life Company that deals with the environment, water and energy, welcomes the EU Commission's proposal to revise the Waste Framework Directive (WFD) by incorporating two of the most resource-intensive sectors, namely textiles and food.

Kimberly-Clark produces Personal Protection Equipment (PPE) for professional use, which encompasses protective apparel, gloves of different compositions and protective eyewear. Many of these products are single use and used, for example, in clean room environments and/or to protect workers from harmful and hazardous substances used in an industrial environment.

Humana LT supports the European Green Deal and joint efforts to fight climate and environmental crises. Being a circular economy company, we advocate for the proposals made by the European Commission and other co-legislators on extending the lifecycle of products, making them more sustainable and reusable.

Confartigianato Imprese is the most representative Italian organisation of crafts and micro and SMEs and one of the most important social partners in Italy. At national level, it counts 104 local associations, 21 regional federations, 1,206 offices and 10,700 employees, offering different types of services to over 1.5 million artisans and small business owners and almost 700.000 enterprises.

The Steel Business Association welcomes the upcoming revision of the EU Waste Framework Directive 2008/98/EC (WFD) with the idea of a stronger focus on circular economy and the objectives of increasing the protection of the environment and public health from the effects of waste management, reducing waste generation, increasing reuse and improving separate collection, as well as promoting preparation for re-use and…

Filed in German · English published by the European Commission

CNA welcomes the willingness of the European Commission to accelerate the green transition of the textile and food sectors. These sectors have an important environmental impact and are strategic for our production system.

Valmet welcomes the Commissions proposal to revise the EU waste framework to better incorporate aspects related to textile waste. Valmet supports extended producer responsibility for textiles to create the necessary economy for collection, sorting, preparation for reuse and recycling, in particular fibre-to fibre recycling, in the EU.

Comments for the Czech Republic: The Czech Republic welcomes the proposed requirements for Member States in the area of measures aimed at preventing the generation of food waste and agrees that measures should be taken for all stages of the food supply chain on an equal footing for all actors at all stages of the food supply chain.

Filed in Czech · English published by the European Commission

The European Consumer Organisation, BEUC generally welcomes the European Commissions proposal introducing binding food waste reduction targets to be met by 2030. Nevertheless, we see some gaps in the legislative text and, in view of its forthcoming amendment by the Council and European Parliament, we would like to share the following comments and recommendations: - The proposed food waste reduction targets are…

Reducing food waste is a global imperative and essential for securing a sustainable future. Its inclusion in the United Nations Sustainable Development Goals underscores the urgency of addressing it, with a view to ensuring responsible resource utilisation and mitigating climate change.

September 2023 EUROPEN contribution to the ex-post consultation on the targeted revision of the Waste Framework Directive EUROPEN, the European Organisation for Packaging and the Environment, fully supports the objective of the European Commission proposal for a targeted revision of the Waste Framework Directive (WFD) to establish food waste and textile waste reduction targets with a view to improve the…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the Proposal for a Directive of the European Parliament and the Council amending Directive 2008/98/EC on waste presented on 5 July 2023 and laying down food waste reduction targets with a view to delivering on the UN SDG 12.3 and F2F Strategy commitments of halving food waste by 2030.

As acknowledged by Eurostat in late 2022, in baseline year 2020, around 131 kilogrammes (kg) of food waste per inhabitant were generated in the EU, and this amount is likely to be underestimated . Therefore, at a time where food waste in the EU has reached records levels, SAFE welcomes the targeted revision of the Waste Framework Directive and the inclusion of new binding food waste reduction targets to be achieved…

Madam, Sir, Paris Good Fashion and Vestiaire Collective are committed to joining forces with EU policymakers to face the challenge of textile waste export. In order to be as useful and concrete as possible, we carried out a 6-month survey and drew up a position paper on behalf of the 100 companies we represent.

Public consultation on revision of EU waste framework In relation to the proposal to amend the Waste Framework Directive COM(2023) 420 final, involving, among other things, the establishment of the Extended Producer Responsibility (ERP) regime for the textile sector, we express our appreciation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

September 9, 2023 Response to the call for evidence about environmental impact of waste management – revision of EU waste framework Sonae is a multinational corporation managing a wide portfolio of businesses in retail, financial services, technology, wood-based panels, shopping centres and telecommunications, creating value across several geographic areas.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached FER comments about the new Proposal for a targeted revision of the Waste Framework Directive. The Spanish Federation of Recovery and Recycling, as an employers' association, brings together the interests of the waste recycling sector and defends them in the different economic, social and environmental fields at national and international level.

FoodDrinkEurope views on EU food waste reduction targets set for food manufacturers under the EC revision of the Waste Framework Directive According to the latest estimates, in the EU, nearly 59 million tonnes of food waste (131 kg per inhabitant) are generated annually with an associated market value estimated at €132 billion euros1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

From the view of the Austrian Chamber of Agriculture we would like to comment as follows: - We agree on the proposal for a revision of the Waste Directive with regard to food waste as it was presented and justified by the Commission.

We agree that no target with regard to food losses in agriculture has been set: According to the Flemish food loss monitor, only 4% of the food produced by the agricultural sector goes. This even includes almost unavoidable food losses such as damaged fruit or losses as a result of preparing products for market (leek greens, onion outer skins).

Dear Ladies and Gentlemen We welcome the European efforts on the political and legislative level to transform the textile market into a circular economy. Against this background, we consider the COM proposal for the new directive to be positive.

EBM welcomes the revision of the EU waste framework as it is clear that further regulatory measures will be needed to ensure a satisfactory transition to a circular economy. Waste prevention has been at the top of the waste hierarchy since its inception, yet decades of practice show it only has this position nominally.

Summary: • more waste handling is expensive, and producers should pay for the impact of their products • possible conflict with state aid rules and polluter pays principle • Extended producer responsibility (EPR) – when well organised – could reduce waste and support circular value chains • local and regional authorities should be a targeted stakeholder The Council of European Municipalities and Regions (CEMR) is…

CLEPA welcomes the revision of the Waste Framework Directive and all efforts to decrease waste by improving the separate waste collection to yield optimal recycling results and minimise the use of raw materials. In the automotive sector the reuse of material in form of remanufactured spare parts is already well established.

Ecoembes and EKO KOM welcome the opportunity to contribute to the revision of the EU’s waste framework. We believe that said review should factor in the potential of waste management operations in contributing to the EU’s climate neutrality ambition and the role that Extended Producer Responsibility (EPR) has to play in this process. Our comments and suggestions are detailed in the attached document.

Brussels, 22nd February 2022 For more information please contact: Eurima - [phone removed] Eurima considerations on the Environmental impact of Waste Management – revision of the Waste Framework Directive The European Commission has adopted the Circular Economy Action Plan in March 2020 - one of the main blocks of the European Green Deal, Europe’s new agenda for sustainable growth.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Mining wastes should be considered as a major waste problem. In Finland the limit for EIA for hazard waste handling is 5000 tons, when it would be disposed on a regular waste dump. However mining wastes are disposed on "mining waste areas" and no EIA is needed even for the environmental permit of Terrafame mine in Sotkamo and Kajaani in Finland.

The Minderoo Foundation welcomes the review of the Waste Framework Directive. To inform this policy process, we would like to submit findings and recommendations from ongoing Minderoo and KPMG research into plastic waste streams in 5 EU countries (FR, GE, IT, NL and PL). 1. Almost half of our plastic waste is not collected for sorting and recycling.

Please find attached ROCKWOOL’s contribution to the consultation on the Roadmap towards the revision of the Waste Framework Directive. In the context of upcoming challenges from deep renovation the construction sector will face in the coming years, ROCKWOOL firmly believes that a meaningful revision of the Waste Framework Directive should support better recyclability.

The EEB welcomes the planned revision of the Waste Framework Directive. In an attached document we describe few directions that this revision should take into account and address: 1. Increasing waste generation (lack of binding waste prevention targets proves lack of action by member states, regions and cities). There is an urgent.

TIE – Toy Industries of Europe wishes to highlight that the revision of the Waste Framework Directive (WFD) is an opportunity to address problems resulting from non-harmonised sorting rules and labelling requirements. At the moment, we experience an uncontrolled growth of national labelling and information requirements, often to be placed on the packaging itself.

In its document accompanying the call for evidence in the context of the revision of the European waste policy, the Directorate-General for the Environment seems to focus exclusively on prevention and re-use measures, ignoring or secondary to other forms of waste recovery and disposal.

Filed in French · English published by the European Commission

Tetra Pak supports the European Commission’s initiative to increase the environmental benefits of waste management and improve waste collection. The review of the EU Waste Framework Directive (WFD) should be aligned with the EU Green Deal key initiatives on Climate and Food and coherent with the new measures proposed in the revision of the EU Packaging and Packaging Waste Directive (PPWD), Sustainable Product…

EDANA, the association representing the nonwovens industry, appreciates the Commission’s call for evidence on the revision of the EU Waste Framework Directive. EDANA supports the general objective of the revision of the Waste Framework Directive (WFD) to improve the overall environmental outcome of waste management in line with the waste hierarchy and the implementation of the polluter pays principle.

Friends of the Earth — JPA welcome the opportunity to comment on the Waste Framework Directive in order to improve the overall environmental impact of waste management in the EU. Below, in a separate file, we provide you with our observations and suggestions aimed at reducing waste generation and its negative impact on the quality of the environment, improving waste sorting at source, producing quality compost, etc.

Filed in Slovak · English published by the European Commission

Dear sir, madam, Please find attached the suggestions from the Dutch Ministry of Infrastructure and Water Management regarding the call for evidence for the revision of the WFD. Feel free to contact me for any further clarification. We would also be available to discuss our suggestions in person. Kind regards, [name removed] Infrastructure and Water Management The Netherlands

The BUND represents more than half a million members and warmly welcomes this initiative. In principle, the use of resources must be significantly reduced. The current Waste Framework Directive does not take sufficient account of overall consumption or resource conservation aspects.

Filed in German · English published by the European Commission

Veolia is the global leader in optimised resource management. The Group designs and provides water, waste and energy management solutions that contribute to the sustainable development of communities and industries.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

A future-proof legislative framework empowering EPR schemes to improve waste management EXPRA’s response to the call for evidence on the Waste Framework Directive Revision EXPRA supports a forward looking and ambitious regulatory framework for waste management which enables national and local entities to implement sound and efficient waste management systems.

Back Market welcomes the initiative to review the Waste Framework Directive to further decrease waste generation and improve waste collection. As the leader of the refurbishment of electric and electronic appliances market, we indeed consider this is a unique opportunity of avoiding WEEE creation by addressing major bottlenecks hampering repair and refurbishment.

The Danish Chamber of Commerce welcomes the initiative to review the EU waste framework Directive. The revision is an opportunity to support regulation that contribute to the transition towards a circular economy. This includes but is not limited to regulation that supports circular business models, harmonization of implementation in Member States and creating a marked for secondary raw materials.

It is our understanding that the European Commission is considering an EU approach to sorting packaging waste and labeling in an upcoming legislation. This is a very positive development which the LEGO Group supports. We also understand that some aspects of a future EU approach might be detailed during the revision of the Waste Framework Directive.

EUCOLIGHT, the European association of lighting WEEE compliance schemes welcomes the European Commission initiative to review the waste framework Directive and its objective to improve the overall environmental outcome of waste management in line with the waste hierarchy and the implementation of the polluter pays principle, potentially via Extended Producer Responsibility schemes.

Ecommerce Europe welcomes the opportunity to provide feedback to the call for evidence for an impact assessment on the revision of the EU waste framework. Waste management plays a key role in decreasing waste generation but also represents an important tool for the transition to a circular economy.

The European Recycling Industries’ Confederation (EuRIC) thanks the European Commission for publishing the Call for Evidence for an Impact Assessment with regards to the revision of the Waste Framework Directive (WFD) and is pleased to provide some preliminary feedback essential for the European recycling industry.

Hazardous Waste Europe (HWE) represents hazardous waste operators present in the whole value chain of hazardous waste management, from collection to final treatment including recycling and regeneration activities in which our members apply the appropriate requirements from the Waste Framework Directive (WFD).

In 2020, the French recycling rate is estimated at 68.2%, slightly lower than the revised 2019 recycling rate of 68.8% . It could be explained by the health crisis in 2020 led to malfunctions in the selective collection system, which collection system, degrading recycling performance.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, is fully committed to the objectives of the European Green Deal and the Circular Economy Action Plan as essential tools for providing the adequate stimuli to our economy while pushing forward EU Climate goals through the circular economy.

The Aerospace Industries Association (AIA) welcomes the opportunity to provide comments on the Environmental impact of Waste Management, the Revision of EU Waste Framework. AIA and our member companies strongly encourages the European Commission to consider amendments to Article 9 of the Waste Framework Directive in order to better protect state security/defense- and space-related technical data from publicly-facing…

The Rethink Plastic alliance welcomes the initiative of the Commission to revise the Waste Framework Directive and the opportunity to provide feedback. The alliance supports the adoption of regulatory measures to reduce waste in absolute terms, and fully apply both the waste hierarchy and the polluter pays principle.

RESPONSE TO CALL FOR EVIDENCE ON THE ENVIRONMENTAL IMPACT OF WASTE MANAGEMENT – REVISION OF EU WASTE FRAMEWORK We at Utilitalia, the national federation of Italian utilities providing public services in the sectors of environment, water and energy, welcome the involvement of stakeholders in the revision of Directive 98/2008/EC, with some initial considerations.

The Waste Framework Directive (WFD) revision will play a crucial role in creating a closed-loop circular economy – also for the garment and textile industry. H&M Group welcomes the opportunity to provide feedback to the WFD roadmap consultation and calls for harmonisation of definitions and requirements across the EU.

Thank you for the opportunity to comment on the EU's waste framework. Vital Strategies is a global public health organisation (with a European office in Paris) devoted to helping the world progress against the rising toll of diseases, including those associated with the built environment.

GROW International welcomes the opportunity to provide feedback on the call for evidence published by the European Commission to review Waste Framework Directive (WFD). We fully support the objective of improving separate waste collection and in particular for wood packaging to yield optimal recycling results.

TOMRA, a leading provider of collection and recycling solutions, supports the upcoming revision of the Waste Framework Directive 2008/98/EC (WFD) and its objective of improving waste management in the EU by, among other things, reducing mixed waste and increasing preparation for re-use or recycling of waste to achieve the set targets.

PGNiG (Polish Oil and Gas Company) welcomes the opportunity to contribute to the Commission’s preparation of an impact assessment for the revision of EU waste framework. HIGHLIGHTS OF THE POSITION • Aims of the initiative should be extended in order to include a promotion of a priority principle for secondary anthropogenic raw materials which support the protection of natural resources.

Feedback vedr. revisionen af EU’s affaldsrammedirektiv I Danmarks Naturfredningsforening, Rådet for Grøn Omstilling og Plastic Change takker vi for muligheden for at indgive feedback vedr. revisionen af EU’s affaldsrammedirektiv. Vi mener, at en revision af affaldsrammedirektivet er et skridt i den rigtige retning, og er generelt positivt stemt over for det fremlagte.

Filed in Danish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Eastman supports the intention of the European Commission to review the Revision of the Waste Framework Directive (WFD) and appreciates the opportunity to contribute to this call for evidence. We support the ambitious goals set in the European Green Deal and EU’s goal to become climate neutral by 2050. We also fully respect the waste hierarchy and, therefore, support an aggressive push toward reduction and reuse.

POSITION PAPER Brussels, 22 February 2022 European beverage carton industry views in light of the call for evidence on the environmental impact of waste management – revision of EU waste framework The Association f or Beverage Cartons and the Environment (ACE), together with its members BillerudKorsnäs, Elopak, SIG Combibloc, Stora Enso and Tetra Pak, welcomes the European Commission’s initiative’s objective to…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Circular Economy for Flexible Packaging (CEFLEX) initiative is a collaboration of over 190 European companies, associations and organisations representing the entire value chain of consumer flexible packaging. Together, we work to make all consumer flexible packaging in Europe circular by 2025.

Waste management done in a responsible and efficient manner is the obvious link offering solutions to two major matters of our time: climate change and the transition to a circular economy. CEWEP supports the efforts of the European Commission to align the WFD to these objectives and offers the following feedback in this context.

We at Neste welcome the opportunity to provide feedback to the European Commission on the review of the Waste Framework Directive and support the Commission’s overarching objective of reducing total waste generation and ensuring high-quality recycling.

Reduction of waste as well as reuse and recycling of waste are all generally important issues for development towards a sustainable society. However, it is of high importance that its not based on rigid rules. If it can be shown, e.g. by LCA that reuse or recycling of a product/material is not the best way (most sustainable) to manage a life cycle, which may be true e.g.

The German Landkreistag recognises the waste management objectives of the European Union and expressly supports them. The review of the existing rules is also warmly welcomed. In this context, a closer look is needed as to which jointly agreed measures can achieve the greatest impact on environmental, climate and resource protection and which measures are difficult to implement in practice or with considerable…

Filed in German · English published by the European Commission

Zero Waste Europe welcomes the European Commission’s initiative to revise the Waste Framework Directive with the aim to improve the overall environmental impact of waste management in the EU. The focus on qualitatively improving the recycling system as well as the focus on waste prevention are of high importance as so far, the EU efforts on circular economy have only led to a quantitative increase in recycling.

The members of the Closed Pallet Pooling Coalition (CPPC) welcome the European Commission’s ambition to revise the EU waste legislative framework to further protect public health and the environment through the proper management of waste. This is done by applying the EU’s waste hierarchy, as defined in the current Waste Framework Directive which promotes 1. waste prevention (reduce) over 2.

France Chimie warmly welcomes the revision of the Waste Framework Directive (WFD), as an opportunity to consolidate certain principles, clarify certain provisions or introduce certain concepts, in line with the objectives of the Green Pact for Europe and its Action Plan for the Circular Economy.

Filed in French · English published by the European Commission

Statement 22 February 2022 EuroCommerce feedback for the call for evidence for an impact assessment about the revision of the Waste Framework Directive Our sector welcomes the planned revision of the Waste Framework Directive (WFD).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Shifting to a circular economy is both an urgent societal necessity, but also an economic opportunity. For the revision at hand, the EU is considering waste prevention measures specifically for the textile sector, whilst also aiming to further boost the fiber-to-fiber recycling industry in the EU. Both efforts will be essential for upgrading the industry towards a circular system.

With the revision of the Waste Framework Directive, the European Commission aims to protect public health and the environment through the proper management of waste. This is done by applying the EU’s waste hierarchy, which promotes 1. waste prevention (reduce) over 2. preparing for reuse; over 3. recycling; over 4. other waste recovery options; over 5. disposal of waste. However, while waste prevention (see No 1.

ACR+ welcomes the European Commission’s proposal to revise the EU Waste Framework Directive. Setting mandatory targets to reduce municipal waste generation is necessary to force national governments and local and regional authorities to take action on waste prevention and to have quantifiable results.

Separate waste collection As a matter of principle, separate collection of waste must be introduced in particular - in order to support the implementation of the waste hierarchy, - in order to achieve the targets for municipal waste or construction and demolition waste, - if it is necessary for compliance with the quality criteria for substitution of primary source materials, - in order to counteract contamination…

Please find in attached document the feedback from Chemical Recycling Europe concerning the Environmental impact of waste management - revision of EU waste management. Best regards, [name removed] Secretary General Chemical Recycling Europe Avenue de Cortenbergh 71 1000 Brussels, Belgium +32.496.255.640

Even though updated not so long ago, the revision of the Waste Framework Directive is highly welcome as the strategy devised in the new Circular Economy Action Plan requires a shift to a better implementation of the waste hierarchy. Indeed, the current waste prevention and preparing for re-use provisions are not concrete enough to lead Member States towards an absolute decrease in waste generation.

EUMEPS (European Manufacturers of Expanded Polystyrene) welcomes the initiative of the European Commission (EC) and shares its stated objectives. With its highly efficient material that consists of 98% air, the EPS industry consistently contributes to waste prevention.

FoodDrinkEurope welcomes the initiative to review the Waste Framework Directive to further decrease waste generation and improve waste collection. To achieve these objectives, a combination of policy options should be considered to ensure an effective implementation of specific waste stream policies under revision, specially the packaging waste directive and specific targets on food waste.

The European Biostimulants Industry Council (EBIC) welcomes the revision of the EU waste framework and would like to contribute to the call for evidence for an impact assessment of the revision of the Waste Framework Directive (WFD) with the comments detailed in the attached document and outlined below.

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the call for evidence for an impact assessment „Environmental impact of waste management – revision of EU waste framework”. Please find detailed comments in the Attachment.

European Commission call for evidence on the revision of EU waste framework - Eni’s response We appreciate the opportunity to express our views on the upcoming revision of the EU waste framework. At this stage, we would like to flag few aspects that will need to be taken into consideration while assessing the policy options to develop a coherent regulatory framework, in line with the EU Green Deal and Circular…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir or Madam, We would like to thank for the opportunity to present our contributions to such a vital topic. As the global leader in refractories, it is our view that RHI Magnesita has a responsibility to lead also on sustainability topics. In the Paper attached we present our feedback based on our long-standing journey towards circularity.

EURATEX actively supports the European Commission’s political commitment towards circular economy and the revision of the Waste Framework Directive (WFD) and welcomes the objectives of the initiative to improve the waste management and the harmonisation of separate waste collection rules across EU. To extend the lifespan of textiles, an appropriate collection system must first be established.

Feedback of Flexible Packaging Europe, the organisation representing the interests of the European producers of flexible packaging The revision of the Waste Framework Directive (WFD) is a necessary complement to the ongoing revision of the Packaging and Packaging Waste Directive.

The Advanced Biofuels Coalition (LSB) welcomes the opportunity to provide comments ahead of the revision of the EU waste framework. In this context, LSB would like to bring the following points to the attention of the Commission: - The ambitious goals to increase the uptake of advanced biofuels available in different modes of transport (including maritime and aviation) will result in larger volumes of waste and…

Brüssel, 22. Februar 2022 Deutscher Industrie- und Handelskammertag Umweltauswirkungen der Abfallbewirtschaftung – Überarbeitung der Abfallrahmenrichtlinie Sondierungskonsultation der EU-Kommission Wir bedanken uns für die Gelegenheit zur Stellungnahme zu der genannten Konsultation.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

• Waste hierarchy: re-use and recycling should be complementary measures We endorse the Commission objective to safeguard the waste hierarchy, and implement measures supporting waste prevention. Turning waste into resources for a circular economy is key in waste prevention; this can be achieved both with recycling and re-use which are equally important in this process.

NABU welcomes the revision of the EU Waste Framework Directive and advocates an ambitious revision. While the existing Directive lays down the waste hierarchy as a guiding principle for managing waste in a resource-efficient way, it does not lay down specific requirements for waste prevention or re-use.

Filed in German · English published by the European Commission

DS Smith plc is Europe’s largest cardboard and paper recycler and is also one of the leading full service recycling and waste management companies in Europe. We collect quality paper and cardboard for recycling from a range of sectors, including retailers, manufacturers, local authorities, and other recycling and waste management companies.

First of all, the new WFD must include waste prevention targets and its implementation should be properly monitored. Romania’s case is known around the EU, strategies, master plans and even EU Directives are adopted or transposed in national legislation, but enforcement lacks. Without prevention targets, the focus will be continuously on recycling and the waste pyramid ignored.

Separate collection of waste Norway supports the EU's plans and the focus of the Waste Framework Directive (WFD) regarding increased recycling of waste and high quality of secondary raw materials. In our view, however, it is unfortunate to have an overly narrow focus on separate collection of waste, when striving to meet these goals.

The Polyolefin Circular Economy Platform (PCEP) welcomes the European Commission’s commitment to “simplify waste management for citizens and ensure cleaner secondary materials for businesses”, along with the overarching commitment to reduce waste.

FIBRE PACKAGING EUROPE supports the EU Green Deal and welcomes the upcoming revision of the Waste Framework Directive. We endorse the Commission’s commitment to optimising waste management systems, ensuring high-quality recycling and cleaner secondary raw materials, and halving the amount of residual (non-recycled) municipal waste by 2030.

Cefic supports the EU Green Deal and Europe’s ambition to become climate neutral by 2050. With this in mind, we welcome the EU initiative to revise the Waste Framework Directive to improve waste management and to reduce the environmental footprint of society. As a Responsible Care®-registered industry sector, we aim at investing in the best available technologies and adopting the best practices to reduce waste.

ETSA, the leading European association for textile rental companies and national textile services associations, welcomes the Waste Framework Directive (WFD) roadmap and its reflection on the environmental impact of waste management and measures to prevent the creation of waste and ensure high-quality recycling.

EUROPEN supports the general objective of the revision of the Waste Framework Directive (WFD) to improve the overall environmental outcome of waste management in line with the waste hierarchy and the implementation of the polluter pays principle.

Essity is a leading global hygiene and health company with sales society in approximately 150 countries and about 46,000 employees (about 1/3rd in the EU). Essity breaks barriers to well-being and contributes to a healthy, sustainable, and circular. We welcome the European Green Deal and we have set an ambitious target to reach net zero by 2050 latest.

DUH welcomes the objective of the initiative to improve the overall environmental outcome of waste management in line with the waste hierarchy and the implementation of the polluter pays principle. Therefore, the introduction of further regulatory measures is inevitable. We would like to comment on the proposed policy options and make further suggestions regarding changes in the WFD.

A circular approach to waste is crucial to reach an absolute decoupling of waste generation and resource depletion from EU economic growth. Overall waste generation has increased the last decade and only limited decoupling has been achieved. Member States seem not to be on track to meet their 2025 EU targets on the preparation for re-use and recycling, especially for municipal waste.

The European Copper Institute (ECI) welcomes the European Commission’s (EC) ambition for proper waste management to protect human health and the environment. The aim of reducing waste generation and landfilling must well remain at the core of the EU waste hierarchy. However, the following approaches and measures should be considered as necessary steps for a fully functioning waste framework. These pertain to: 1.

With this initiative, the EU Commission intends to revise the EU Waste Framework Directive. One of the main objectives is to better implement and strengthen the EU waste hierarchy in order to optimise waste prevention, preparation for re-use and recycling. In principle, this goal of the EU Commission is supported by VCI. The chemical industry is making a variety of contributions to this.

ZERO welcomes the opportunity to provide feedback to enhance the potential of the WFD to be a promoter of Circular Economy in the EU. We have the following suggestions, organized in three main themes: 1. Adopt binding waste prevention (reduction and reuse) targets.

ESPP (European Sustainable Phosphorus Platform) supports the need to improve waste prevention and separate collection. In particular, separate collection of (non-avoidable) food waste and organics is important (including from caterers, restaurants), in order to enable recycling of phosphorus, other nutrients and organic carbon, by e.g.

For the EU to transition to a resource-efficient circular economy, preventing waste is a key element. With large volumes of waste still being generated, novel technologies for waste disposal could play a crucial role to reach this transition.

Among its members, MPE has representatives of aluminium and steel sectors. These 2 sectors are top performers in recycling packaging materials. With respective rates of 76%, and 84% our industries have worked closely with European, national and local authorities, Extended Producer Responsibility Schemes, waste management operators and, last but not least, customers, brands and civil society at large, to invest in…

Eurits [the European Union for the Responsible Incineration and Treatment of Special waste] is an association of hazardous waste management companies all of whom operate dedicated high-temperature incinerators for the treatment of hazardous waste as well as a wide variety of recycling and recovery facilities for both hazardous and non-hazardous wastes.

One of the main objectives of the WFD revision initiative is to reduce the quantities of mixed waste destined to disposal and incineration and to increase recycling rates. To do this, the separate waste collection needs to improve in quality and quantity, to increase the percentage of waste sent to recycle. However, this is not enough: the recyclability rate of the collected plastics also must improve.

Oblige Member States to set legally binding, specific numerical targets for increasing reuse. — International analyses between voluntary targets for large producers and actual results illustrate the worrying gap in waste prevention and recycling.

Filed in Estonian · English published by the European Commission

IKEA fully supports the goal of the Commission of improving waste management and building the preconditions for a well-functioning market of secondary raw materials. In addition to the topics identified in the call for evidence, a revision of the Waste Framework Directive (WFD) should take into account the following: 1) Revisit the waste definition in light of the circular economy: the legal definition of “waste”…

Syctom is the Metropolitan agency for municipal waste in the Paris region and Europe's largest public operator of municipal waste. As a public service, Syctom strongly supports the European Green Deal and the New Circular Economy Action Plan (NCEAP), especially the objective to significantly reduce total waste generation and halve the amount of residual (non-recycled) municipal waste by 2030.

Hello, I write to you on behalf of the RDF Industry Group regarding your draft revisions to the EU Waste Framework Directive (WFD). Our Group represents 33 organisations across the European waste derived fuel (WDF) supply chain, including WDF production companies who produce fuel from residual waste, energy-from-waste (EfW) facility operators, and those who ship, transport and test WDF.

Revision of the WFD is a chance to move up the waste hierarchy toward prevention and reuse, supporting the development of reuse infrastructure while still embracing the polluter pays principal. * We call for a per capita residual waste target of 100kg or less to encourage waste reduction and quality material recycling/composting.

In the context of climate change and saving of resources, Eucopro is committed to promote the transition towards a circular economy. Eucopro welcomes this initiative from the European Commission. Eucopro 's comments are included in the joined Position Paper.

Revision of EU waste framework APK AG, an innovative plastics recycling company and technology developer from Merseburg (Germany), welcomes the legislative review of the Waste Framework Directive, which represents a milestone towards achieving circularity for plastic packaging.

AVR is an advanced waste treatment facility based in Rotterdam and Duiven (NL). AVR strives to retrieve maximal value from mixed household waste, commercial and industrial waste in a circular and environmentally sound manner. AVR welcomes the European Commission’s proposal for a review of the Waste Framework Directive (WFD).

The HUMANA members across Europe thanks the Commisssion for the opportunity to comment on the ongoing initiative of the EC to revise the Waste Framework Directive based on the requirements of the European Green Deal and the Circular Economy Strategy.

CELPA - The Portuguese Pulp and Paper Association welcomes the revision of EU waste framework. We endorse the policy maker’s intention to optimise waste management systems to support higher recycling rates, cleaner secondary raw materials, to halve the amount of residual (non-recycled) municipal waste by 2030, and to ensure high-quality recycling.

In our perception the current legislation needs to be enforced and expanded upon. The biggest opportunity to meet the Global Methane Pledge target according to the UN's Global Methane Assessment is to limit the amount of landfilling of waste. The landfill target of 10% MSW needs to be extended to commercial & industrial waste.

PepsiCo welcomes the opportunity to provide input to the call for evidence in view of the impact assessment that will support the review of the Waste Framework Directive. This legislative review will mark a major milestone towards achieving the end of landfill and incineration of packaging - plastic packaging in particular - by setting high recycling targets, enforcing effective separate collection, strengthening…

22 February 2022 Response to Call for Evidence on the Environmental impact of waste management Revision of EU Waste Framework Municipal Waste Europe welcomes the direction towards Climate Change Mitigation put forward by the European Green Deal and the Circular Economy Action Plan 2.0, both launched in 2020.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FEP – the European Federation of the Parquet industry – is welcoming the Call for Evidence on the “Environmental impact of waste management – revision of EU waste framework” and the possibility to comment it. FEP is supporting the waste hierarchy as set by the EU waste framework, favouring waste prevention over re-use, recycling, other waste recovery options and disposal.

Stora Enso is a renewable materials company and one of the largest private forest owners in the world, employing 18 000 people in the EU. We deliver renewable and recyclable products that store carbon and provide low-carbon alternatives to fossil-based materials.

Clariter welcomes the Commission’s initiative to revise the Waste Framework Directive (WFD) and would like to thank them for the opportunity to contribute to the ongoing stakeholder consultation. We welcome the alignment and cohesion between the implementation of the Waste Framework Directive with the goals of the European Green Deal as well as the Circular Economy Action Plan and the Packaging and Packaging Waste…

Food waste collection (and – prevention) is crucial for the objectives of the waste framework directive. Zero Waste Europe reported that only 26% of the food waste generated is separately collected. This means that the majority of food waste is landfilled or incinerated.

I am Clarissa Morawski CEO and co-founder to Reloop Platform. We are submitting a commissioned report by Dr. Dominic Hogg, The Case for Sorting Recyclables from Residual Waste. The report is comprehensive in its scope, and addresses proposed changes to the WFD, while at the same time offering additional proposals for complimentary policies within the EU.

The Policy Hub - Circularity for Apparel and Footwear welcomes and supports the European Commission’s proposal to revise the Waste Framework Directive (WFD). The ambition of the Policy Hub is to improve the circularity of the textile sector by maintain-ing as much as possible value of resources used in the production of textile products.

JBCE is pleased to contribute by actively taking part in public consultations and hearings. The measures should be functional and effective to achieve the ambitious goal. For that we suggest following points: •Before a new system is introduced, socio impact assessments should be always carried out to find out the most efficient way and figure out whether the benefits excess the burden in the whole society.

The VÖA - Association of Public Waste Management Companies welcomes the targets presented by the European Commission to reduce waste generation and to improve separate waste collection in the sense of a sustainable circular economy. Product legislation (e.g. "design for recycling" and "design for collection") must be integrated into the concept of circular economy.

ERFO welcomes the initiative of the European Commission that aims to improve the overall environmental outcome of waste management. The Waste Framework Directive has served well to improve the management of waste in Europe. Revising it may offer opportunities to improve the way in which waste is handled even further. For that good separation at source is required.

Confederation of Danish Industry (DI) on call for evidence on EU Waste Framework DI strongly supports the measures in the Waste Framework Directive and the political commitments in the European Green Deal and the Circular Economy Action Plan the crux of which we consider ensuring high quality recycling.

ECMA supports the ambition of the EU Green Deal and welcomes the upcoming revision of the Waste Framework Directive, which offers the opportunity to decrease waste generation and optimize recycling. The paper and board industry has invested heavily over decades to build the infrastructure to ensure our products are collected and recycled – indeed more paper and board packaging is recycled, by volume, than all other…

We support the Commission's efforts to improve the state of the environment with waste management in accordance with the waste hierarchy. However, the entire waste management value chain must be taken properly into account to reach the waste management and circularity goals set by the EU.

European Aluminium welcomes the Commission’s intention to revise the EU’s waste framework. Modernising waste legislation is a timely and necessary step to establish a resource-based framework fit for the transition to a Circular Economy and well-equipped to meet the objectives of the European Green Deal.

European Recycling Platform (ERP) welcomes the Commission’s initiative to revise the Waste Framework Directive (WFD) and would like to thank them for the opportunity to contribute to the ongoing stakeholder consultation.

ALPLA has over 25 years of experience in PET/PO packaging recycling. With our recycling plants, we ensure that plastics remain in the material cycle. We are also a competent partner for processing recycled post-consumer plastics (PCR) into new, high-quality packaging. We hereby point out enabling measures for circular (plastic) packaging and products as well as the reduction of plastic waste.

Niaga® is on a mission to design out waste, completely. We redesign products for circularity so materials do not end up as waste and are used again and again. A product is only truly circular if it contains clean and infinite materials, reversible connections and when it is returned for material reuse – meaning return is key.

The European Paper Packaging Alliance (EPPA) supports the EU Green Deal and welcomes the upcoming revision of the Waste Framework Directive. We endorse the Commission’s commitment to optimising waste management systems, ensuring high-quality recycling and cleaner secondary raw materials, and halving the amount of residual (non-recycled) municipal waste by 2030.

The EU can play a key role in curbing ocean plastic pollution at source According to the most recent peer-reviewed scientific studies, an estimated 15 million tonnes of plastic are dumped into the world’s ocean every year.

The European Panel Federation (EPF) welcomes the opportunity to provide feedback on the call for evidence for an impact assessment on the revision of the EU Waste Framework Directive (WFD). EPF believes that the sound implementation of the waste hierarchy established in the WFD favouring the prevention of waste and material use over disposal and early energy recovery is of the utmost importance to uphold the…

The Confederation of European Paper Industries-Cepi welcomes the revision of EU waste framework. We endorse the policy maker’s intention to optimise waste management systems to support higher recycling rates, cleaner secondary raw materials, to halve the amount of residual (non-recycled) municipal waste by 2030, and to ensure high-quality recycling.

The European Snacks Association asbl (ESA) is Europe's only trade organisation dedicated to advancing the savoury snacks industry. The majority of savoury snacks are packaged using flexible laminated plastic films because they are one of the most resource efficient options which are currently available.

Plastics Europe supports the intention of the European Commission to review the WFD and appreciates the opportunity to contribute to this call for evidence. We provide the following feedback on behalf of European plastics manufacturers and are available for further dialogue on this matter: - Plastics Europe welcomes the revision of the Waste Framework Directive (WFD) with a view to support the EU climate ambition…

Reaction ‘Call for Evidence - Revision Waste Framework Directive’ - Recycling Netwerk Benelux As an environmental organization we endorse the European Commission’s initiative to revise the Waste Framework Directive, but fiercely encourage to explicitly include resource reduction as the main aim of a circular economy.

APEAL, the Association of European Producers of Steel for Packaging, unites the six producers of steel for packaging in Europe, welcomes the revision of the Waste Frame Directive and believes that this revision should (1) consider further finetuning the waste hierarchy, (2) support “real” recycling, (3) promote optimised separate collection and (4) reduce food waste.

Novelis is the world’s largest recycler of aluminium and the largest supplier of flat-rolled products made from recycled aluminium. Over the last decade we have invested heavily (over 600 million Euros globally) to grow our recycling capabilities, and we recently announced additional recycling investments of close to 400 million Euros. As a result, we use on average 61% of recycled material today.

Subject: call for evidence – revision of the EU waste framework 4evergreen is glad to engage with the Commission on the the revision of the EU waste framework. We would like to share information on the guidelines that 4evergreen is developing, which we believe relevant to take note of when revising the EU waste framework.

VNO-NCW and MKB-Nederland support the Commission’s objective to improve waste management by reducing waste generation and mixed waste, and increasing preparation for re-use or recycling of waste by improving separate collection. Therefore we support revision of the Waste Framework Directive by introducing measures that can create a European market for secondary raw materials.

The Association of Municipal Enterprises (VKU) e.V. welcomes the European Commission’s initiative to review the 2018 Waste Framework Directive. This is an important and appropriate step to reduce waste generation and improve separate collection.

Filed in German · English published by the European Commission

Brussels, 21 February 2022 Environmental impact of waste management – revision of EU waste framework Dear Sir/Madam, Thank you for the opportunity to comment on the call for evidence for the impact assessment related to the review of the Waste Framework Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ESWET - the association representing European Suppliers of Waste-to-Energy Technologies - welcomes the Commission roadmap on the Environmental impact of waste management and is fully in support of waste reduction. However, while waste prevention is the most desirable goal in the long-term, waste generation is still on the rise in Europe and needs to be dealt with, including non-recyclable waste.

FuelsEurope supports the goals of the Paris Agreement and the EU’s objective of climate neutrality by 2050, and welcomes the publication of the New Industrial Strategy for Europe and the Circular Economy Action Plan as key enablers for the European Green Deal, projecting EU competitiveness in a global dimension and allowing the deployment of low-carbon technologies.

The European Commission is looking at revising the Waste Framework Directive in order to improve recycling and reuse of wastes and products and to specifically address oil wastes. EurEau, the European Federation of Water Services, represents waste water services providers who can recover a lot of materials from urban waste water treatment streams.

General: NRK Recycling welcomes the revision of the Waste Frame Directive The crucial elements for the recycling industryu in the coming years are: Recycling of plastic waste streams is crucial to achieve a circular economy. Waste is the new source of raw material. Separate collection of waste is crucial for processing high quality recycled materials.

To Of the European Commission Responding to the Commission’s call for evidence in the process of reviewing the EU framework on waste in terms of the environmental impact of waste management, Poland Association of Opon recyclists, representing ca.

Filed in Polish · English published by the European Commission

MedTech Europe - the European trade association for the medical technology industry, including diagnostics, medical devices, and digital health - welcomes the opportunity to contribute to the call for evidence for an impact assessment regarding the initiative on the revision of the EU Waste Framework.

Attached is feedback submitted on behalf of European Bioplastics. The members of European Bioplastics (EUBP) support an ambitious Green Deal that is committed to significantly reducing waste generation, simplifying waste collection for citizens, and ensuring cleaner secondary materials creating a sustainable competitive advantage for the European industry.

The Europaen Solvent Recycler Group - ESRG - fully supports the waste hierarchy but our experience is that waste generators and producers tend to make their waste management decisions on the cost of treating waste rather than any holistic environmental benefit. This suggests the waste hierarchy is not working efficiently.

Kimberly-Clark’s Submission to the European Commission Consultation on the Roadmap towards the planned revision of the Waste Framework Directive Introduction We welcome the European Commission’s Initiative to revise the Waste Framework Directive (WFD) with the goal to prevent waste more effectively, increase waste collection and recycling rates and ensuring waste conversion into secondary raw materials which can…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Het Groene Brein is a group of leading Dutch academics that joined their brain power in support of the circular economy. Het Groene Brein is worried about the way in which the European Commission wants to revise the Waste Framework Directive, because Het Groene Brein is worried about how the Commission equates waste policy with circular economy policy.

We welcome the revision of EU waste framework. We endorse the policy maker’s intention to optimise waste management systems to support higher recycling rates, cleaner secondary raw materials, to halve the amount of residual (non-recycled) municipal waste by 2030, and to ensure high-quality recycling. Circular economy is one of the building blocks to achieve climate neutral Europe by 2050.

please see the attached paper from ECBPI which focusses upon soil health in the context of biowaste management. Biowaste is different to other wastes streams in that its outputs end up in Nature, therefore the legislator needs to concentrate on how to reduce contaminants in the inputs to avoid negative impacts when biowaste outputs are spread to soil.

The European Chemical Regions Network (ECRN) is striving for a circular economy. A fully circular economy starts with smart design and the use of discarded materials for products with an equal or higher value. Waste flows are not limited to regional and national boundaries.

Thank you for your opportunity to express your views on a matter that we are familiar with. The world of waste in Italy is complex and the rules are complicated precisely because of the legislation that is not easy to apply to producers and can be interpreted differently. The main problems in our view are: 1.

Filed in Italian · English published by the European Commission

FIR welcomes the initiative of the Commission to improve the overall environmental outcome of waste management. FIR represents the recycling industries of construction and demolition waste and of incinerator bottom ash. The initiative offers opportunities to improve the management in Europe of these vast waste streams. Attached is our feedback to the call for evidence.

The Confederation of European Paper Industries-Cepi welcomes the revision of Waste Framework Directive. We endorse the policy maker’s intention to optimise waste management systems to support higher recycling rates, cleaner secondary raw materials, to halve the amount of residual (non-recycled) municipal waste by 2030, and to ensure high-quality recycling.

As stated by the Development Goals of the UN Agenda 2030, a safe management of waste (solid and sludge/biosolids generated from wastewater treatments) with a view to an effectively sustainable development is fundamental to the health of communities and to their socio-economic development.

The current law is the collapse of recycling companies, the black market for waste and the increase in prices through market monopolisation. Hundreds of tires of rubbish in old gravel plants, rivers, rented facilities and hundreds of arson. Changes to the rules are happening with criminals, and recycling is at risk of millions of fines and imprisonment.

Filed in Polish · English published by the European Commission

SNCF, Société Nationale des Chemins de Fer français, has made the circular economy one of its strategic projects. SNCF has a first track record. However, these experiments confirm that the development of the circular economy within businesses is hampered by waste regulation and its lack of articulation with circular economy ambitions.

Filed in French · English published by the European Commission

With the presentation of the Circular Economy Action Plan, the European Commission had also announced a revision of the Waste Framework Directive (WFD). With a ‘Call for Evidence’ (CFE), the Commission is currently identifying possible priorities for the impact assessment and is thus launching the revision.

Filed in German · English published by the European Commission

The Austrian Federal Economic Chamber would like to thank you for the opportunity to comment on the ongoing initiative of the EC to revise the Waste Framework Directive based on the requirements of the European Green Deal and the circular economy strategy with the objectives — reduction of the Waste generation, i.e.

Filed in German · English published by the European Commission

Evonik welcomes the revision of the Waste Framework Directive to support the EU’s climate and circular economy objectives. The Waste Framework Directive, which is mainly designed for a linear economy, needs to be adapted to the requirements of a circular economy. This requires, inter alia, a fundamental new definition of ‘waste’. What is now regarded as waste must in future be regarded as a raw material.

Filed in German · English published by the European Commission

FNADE, the French private companies’ association for waste management and environmental services, welcomes this new initiative from the European Commission in order to reduce waste production, to improve separate waste collection and high-quality recycling avoiding contaminations and to promote oils regeneration. Please find FNADE's feedback attached.

Knauf Insulation has more than 40 years of experience in the insulation industry and is one of the fastest growing and most respected names in insulation worldwide. We are committed to help our customers to meet the increasing demand for energy efficiency and sustainability in new and existing homes, non-residential buildings and industrial applications.

Overall, we are looking very much forward to a revision of the Waste Framework Directive. Among other initiatives, we are especially hoping for a new recycling hierarchy. We naturally support that prevention of waste generation and reuse have priority over recycling. Concerning this matter, we’ve found that designs promoting circularity is a key action area.

Health Care Without Harm (HCWH) Europe welcomes the initiative to review the EU waste framework and to decrease the negative environmental impacts of waste management. HCWH Europe agrees that the priority objective of the initiative should be to decrease waste generation altogether - this can be achieved by respecting the waste hierarchy and looking firstly at upstream solutions.

Ceramic food packaging as a niche for EU SMEs According to Eurostat Data (2021), the Ceramic Industry in the European Union produced an added value at a factor cost of € 10.4 billion in 2018, of which the Ceramic Industry in Southern Europe produced 54%.

CITPA supports the ambitions of the Commission introduced with the EU Green Deal and the present EU initiative aiming to “decrease waste generation and improve separate waste collection to yield optimal recycling results”. The paper and board industry has invested heavily over the last decades in infrastructure to ensure paper and board packaging is collected and recycled.

FEFCO supports the ambition of the EU Green Deal and is ready to contribute to the objective of the present EU initiative to “decrease waste generation and improve separate waste collection to yield optimal recycling results”. The call for evidence aims to tackle the continued increase in total waste generated, due partly to low recycling rates and low quality recyclates.

Response to Environmental impact of waste management – revision of EU waste framework Samfunnsbedriftene - Association of Norwegian Muncipal Enterprises represents municipalities who are responsible for fulfilling EU/EEA legislation on waste in Norway.

Finnish Forest Industries Federation (FFIF) reply to Commission call for evidence for an Impact Assessment: Environmental impact of waste management – revision of EU waste Framework. FFIF supports the policy maker’s intention to optimise waste management systems to ensure high-quality recycling, including higher recycling rates and good quality secondary raw materials.

Feedback from the German Environment Agency Any views expressed are those of the German Environment Agency and may not in any circumstances be regarded as stating an official position of the German Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) of the Federal Republic of Germany.

Fortum welcomes the initiative to revise the waste directive with the aim to improve waste management to move further up in the waste hierarchy. Regarding incineration of residual waste, currently new techniques are developed and residues from incineration of waste that historically has been disposed of may be recovered for valuable minerals and metals, which in turn can be recycled into recycled raw materials.

The Call for Evidence highlights some specific points on waste oil. In particular: • the possibility that illegally disposed oils still remain in the EU; • the environmental problem resulting from the destination of 39 % of waste oils when burning instead of regeneration (at European average level).

Filed in Italian · English published by the European Commission

LanzaTech welcomes the EU Commission’s proposal to revise the Waste Framework Directive. The Waste Framework Directive is a crucial legislative instrument to achieve the EU Commission’s goals set out in the European Green Deal and the Circular Economy Action Plan. The Circular Economy Action Plan commits to significantly reducing total waste generation.

The Association of Nordic Engineers (ANE) looks forward to a review of the Waste Directive — we hope, among other things, that there will be a new waste hierarchy. We support waste prevention and reuse ahead of recycling, energy recovery and disposal. In particular, we consider that design for circularity is an extremely important effort.

Filed in Danish · English published by the European Commission

In the Plastindi industry in Denmark (www.plast.dk), we are very looking forward to the review of the Waste Directive — in particular, we hope that a new waste hierarchy will emerge. We support waste prevention and reuse ahead of recycling, energy recovery and disposal.

Filed in Danish · English published by the European Commission

The focus of the current proposal on the strategic direction of the upcoming waste framework di-rective on waste prevention and better separate collection of the different waste types for better reuse und recycling is certainly valid. There, however, is some danger that the directive only pushes for measures to be continued which are already in place.

— The Commission needs to put more focus on the pursuit of a toxic-free environment and to levy the tax loop through regulation ensuring that hazardous substances do not recirculate in recyclaes.-Waste Sweden also notes that there are previous Commission proposals that relate to Waste Sweden’s position that taxes and levies can be used to manage waste management.

Filed in Swedish · English published by the European Commission

Dear Sir or Madam, I would like to comment on the impact assessment on the revision of the Waste Framework Directive. The district of Wesel explicitly recognises and supports the European waste management objectives to date. In order to increase effectiveness, the district of Wesel recommends prioritising waste management objectives and concerted action across Europe.

Filed in German · English published by the European Commission

The procedure to define an end of waste should be simplified and should be faster, and it should be harmonized at EU level. Specially for UCOME (biodiesel made out of used cooking oil), a clear end of waste definition is needed as in this specific case it is still not approved by most of the Member States.

Food waste collection (and – prevention) is crucial for the objectives of the waste framework directive. Zero Waste Europe reported that only 26% of the food waste generated is separately collected. This means that the majority of food waste is landfilled or incinerated.

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.

The Federation of Norwegian Industries support the goals of waste reduction and increased recycling rates within the EEA-area. In addition to Waste Framework Directive, measures for waste reduction should be implemented in European product legislation and by introducing new incentives as right to repair, environmental labelling, etc. For complex industrial waste streams (e.g.

1. Collection, sorting & recycling of plastics In order to increase the circularity of plastic materials it is needed to act on the three steps of the end of life treatment: collection, sorting and recycling. Regarding collection of plastics, it would be necessary to have a clear and harmonized labelling thus to would help consumers to correctly dispose it. Sorting technologies have been improving over the years.

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the initiative’s objective to harmonise separate waste collection rules at EU level. Our association supports the revision of the Waste Framework Directive (WFD)1 as an opportunity to introduce measures that lead to a clear harmonised distinction between waste as a resource from waste to be disposed of.

I think it is essential to work on a harmonised recycling system for all member states to reach the European recycling targets and better recyclate qualities. In my opinion we need to establish a common marking and collection system for all major industries to ensure that there are no SOVHC included and to, at least, separate legacy products with harmful ingredients like lead stabilisers.

Residents should be encouraged to reduce waste generation. Those who produce less waste and sort should pay less. For families with more children, although they sort and produce little waste, fees are a heavy burden as they are paid for each child in the same way as for adults, including newborns. Unfortunately, we do not know how to prove that someone produces less waste and does not need to go to nature.

Filed in Czech · English published by the European Commission

Waste management 27012022 Dear European Commission, DG Environment B3, Dear Greens/Lander, A Senior Corporate Silver Spoon, Environment & Nature Association [TR ID: 30399232694-16] on behalf of you, we thank you for your call for an opinion on waste management.

Filed in Hungarian · English published by the European Commission

"Eco-modulation of fees for ‘greener’ products" (2021) argues that it is inherently impossible to have a wide, comprehensive, and ambitious EPR scheme where EPR financial contributions do not exceed the costs that are necessary to provide waste management services in a cost-efficient way, and yet has a discernible effect on consumer and producer behaviour.

Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE) (hereinafter “the Directive”) says that from 2019, the minimum collection rate to be achieved annually shall be 65%(1) of the average weight of electrical and electronic equipment placed on the market in the three preceding years in the Member State concerned, or alternatively 85% of WEEE Generated (WG) on the territory of that Member State.

Proposal for a revision of Directive 2008/98/EC on waste – food waste reduction target Position paper Annually, an estimated volume of 88 million tonnes of food, equalling up to 20% of the entire production, is wasted in the European Union 1, whilst 33 million people are not able to afford meals of good quality every other day.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Apeel Sciences Response to the Inception Impact Assessment on Food Waste Reduction Targets October 29, 2021 Apeel Sciences (hereafter “Apeel”) welcomes the European Commission’s proposal for a ‘revision of Directive 2008/98/EC on waste—part on food waste reduction target’.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We welcome the intention of establishing binding food waste reduction target(s), as at these have proven to be effective in Slovenia time and time again. It may also be beneficial to consider separate targets for food losses, additionally since there is risk that food loss prevention will sometimes be reported as food waste prevention.

Euro Coop lauds the European Commission's initiative to take action against food loss and waste by setting legally binding targets to halve food waste across the EU by 2030. As ethics-based, values-led and principled-driven retailers, consumer co-operatives place sustainability in its economic, social and environmental dimensions at the core of their action.

FTS is an industry association representing the Controlled Environment Agriculture (CEA) sector, a fast-evolving emerging solution that has the potential to greatly improve and diversify the inclusiveness, sustainability, and competitiveness of all food systems, in line with the EU policy objectives (e.g. Green Deal). CEA deploys technology based on imitating natural processes (i.e.

Ladies and Gentlemen, First of all, the National Poultry Council – Chamber of Commerce (KRD-IG) would like to thank the Commission for being able to comment on the preliminary impact assessment of the proposal to amend Directive 2008/98/EC on waste – part on the objective of reducing food waste.

Filed in Polish · English published by the European Commission

Slow Food Feedback on the EU Inception Impact Assessment: Proposal for a revision of Directive 2008/98/EC on waste – part on food waste reduction target. 29 October 2021 As a member of the EU Platform on Food Waste and Food Losses, Slow Food welcomes the European Commission’s initiative on the setting of EU-level targets for food waste reduction, and strongly recommends that a binding 50% reduction target on food…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We fully support the implementation of legally binding targets for member states to reduce food waste. We agree that these need to be ambitious and aligned with SDG 12.3 (50% reduction - but across the full food chain) in order to drive the climate action we need to avert a climate catastrophe. The targets must be applied from farm to fork.

Too Good To Go welcomes the opportunity to provide comments to the European Commission’s Inception Impact Assessment concerning the setting of legally binding targets to reduce food waste. Current food loss and waste levels in the EU are responsible for unacceptable resource inefficiencies and are a major contributor to unsustainable food systems.

A key element of the Farm to Fork Strategy, eliminating food loss and waste to the largest extent possible is an urgent and indispensable step towards more sustainable food in the EU. Therefore, WWF welcomes this European Commission initiative to establish legally binding targets to reduce food waste, and the opportunity to provide feedback on the inception impact assessment.

Copa and Cogeca welcome the Commission proposal to fix reduction targets for Member States, however, this process needs to follow a carefully designed and incremental plan as set in Directive 851/2018/EC amending Directive 2008/99/EC on waste. Furthermore, the imbalances of power in the food value chain need to be taken into account as to ensure a fair repartition of responsibility between all actors.

Thank you. I welcome the Commission’s Roadmap and the opportunity to submit a response. I strongly recommend the Commission should adopt Option S1 to provide equal treatment for all stages of the supply chain and comprehensive coverage rather than limiting scope to cover retail and consumer sectors only.

We, the Federal Association of the German confectionery industry (BDSI), thank you for the opportunity to comment on the roadmap for “Reducing food waste — Targets”. The German confectionery industry is committed to reducing food waste and is already ready to minimise avoidable food waste.

Filed in German · English published by the European Commission

Freshfel Europe, the European Fresh Produce Association, welcomes the European Commission’s proposal for a ‘revision of Directive 2008/98/EC on waste – part on food waste reduction target’. This initiative under the Farm to Fork Strategy will further stimulate Europe’s food waste reduction efforts throughout the agri- food supply chain for a more sustainable food system in line with the European Green Deal’s…

Independent Retail Europe welcomes the ambition of the Commission to reduce food waste. With 20% of all food produced in the EU ending up as waste and 88 million tons of food waste generated annually, we fully recognise the need to continue the effort to reduce food waste. Retailers have developed or engaged in numerous initiatives to reduce their actively generated food waste to a minimum.

City of Copenhagen supports the establishment of specific targets for food waste reduction. This primarily applies to setting targets for food waste that originates in public kitchens e.g., in day care centers, schools and nursing homes. The appropriate approach for the targets is to be set up in am manner where they are easy to monitor.

The German deep-freezer institute (Dti) supports the European Commission’s Farm-to-Fork Strategy. Reducing food waste is an important lever to prevent emissions and manage the planet’s natural resources efficiently. It is important and correct that all actors in the value chain must make their contribution to reducing food waste.

Filed in German · English published by the European Commission

Position paper October 2021 Making Retail and Wholesale part of the solution to fight food waste Key messages • • • • Retailers and Wholesalers have been extremely successful in tackling food waste both within their own operations and by working with suppliers and consumers. Retail and Wholesale account for 5% of total food waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

UECBV - the European Livestock and Meat Trades Union - supports the Commission’s initiative to reduce food waste and contribute to sustainable food systems. We would like to remind the Commission about the efforts made by the slaughterhouses, turning bio-waste, residues, and discards into valuable resources, and bring the most value of the carcases to support the nutritional circulations which is vital for both…

Food waste is a missed opportunity to feed the growing world population, a major waste of resources and a needless source of emissions. The food and drink industry is committed to contributing to the implementation of UN Sustainable Development Goal (SDG) 12.3 which targets to halve per capita food waste at the retail and consumer level by 2030, and reduce food losses along the food production and supply chains.

Oddbox welcomes the roadmap as a purpose-led business with a vision to ensure that all food grown is eaten. We strongly recommend that the Commission models a 50% reduction of FLW (food loss and waste) for all EU member states under Step 2 Option 3 (rather than 40-50% reduction) and puts forward a legislative proposal for all member states to meet a 50% reduction of FLW from farm to fork by 2030, ideally by Q4 of…

Coldiretti, the main agricultural organization in Italy and across Europe covering all the productive sectors (from agriculture to fishery and forestry) and the whole agri-food value chain, and representing 1.6 million members and nearly 500.000 farms across Italy, welcomes the opportunity to provide a feedback on the European Commission roadmap aiming at reducing food waste along the whole agri-food chain.

On behalf of the Hungarian Ministry of Agriculture, the National Food Chain Safety Office and the "Wasteless" national food waste prevention programme we support for the following approach: Option S1 - target covering the whole food supply chain, from farm gate to final consumer Reason: If only some of the actors would be selected, venues of food waste generation might be shifted along the food chain to unregulated…

AVEC representing the EU poultry meat sector would like to thank the Commission for giving us the opportunity to comment on this inception impact assessment on the proposal for a revision of Directive 2008/98/EC on waste – part on food waste reduction target.

The prevention, collection and organic recycling of bio-waste is one of Europe’s biggest challenges. The New Waste Framework Directive (WFD), included in the Circular Economy Package, mandates the introduction of separate collection of bio-waste as of 1 Jan 2024.

Environmental Action Germany (Deutsche Umwelthilfe e.V. - DUH) strongly welcomes the initiative to propose legally binding targets to reduce food waste in the EU. Concerning the scope of the policy scenario, DUH urgently recommends to promote Option S1, establishing a target covering the whole supply chain from farm-level production to the final consumer.

Towards a zero food waste food system Zero Waste Europe welcomes the initiative of the European Commission to start the process to set-up binding food waste reduction targets across the EU. Food waste is a multifold problem that not only causes environmental and climate damage but is also morally unacceptable.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Nutreco fully supports the ambitions of the European Commission to reduce food waste along the food chain by 50% in 2030. This contributes to reduction of overall GHG emissions and supports the deployment of a sustainable European bio-economy. We ask attention for the following points: • It may not be helpful to consider these streams as ‘waste’ both from communication as well as regulatory point of view.

Thank you for the opportunity to comment on the roadmap on the future initiative on a binding food waste reduction target. German food retailers pay particular attention to minimising food losses. In doing so, they contribute to the conscious and sustainable management of resources. On the other hand, they reduce the loss of turnover and revenue.

Filed in German · English published by the European Commission

Food waste - reduction targets FoodWIN & Bond Beter Leefmilieu 29 october 2021 We welcome the Commission’s Roadmap and the opportunity to submit our response. As Bond Beter Leefmilieu, federation of the environmental organisations of Flanders, Belgium, and FoodWIN, a Belgian NGO dedicated to tackle food waste (member of the EU’s Platform FLW), we strongly recommend that the Commission puts forward a legislative…

WRAP welcomes the initiative to establish EU-level mandatory targets for food waste reduction, and the opportunity to submit our feedback. Tackling food waste is key in achieving not only SDG 2 and 12.3., but also in achieving Net Zero, reducing GHG emissions and increasing resource efficiency across the food value chain, while alleviating pressure on the natural environment.

SMEunited shares the Commission's objective of working to reduce food waste. A reduction in food waste and surpluses is of primary importance both for reasons related to the improvement of environmental sustainability and for what concerns the reduction of production costs faced by Crafts and SMEs.

We welcome the Commission’s Roadmap and the opportunity to submit our response. As Bond Beter Leefmilieu, federation of the environmental organisations of Flanders, Belgium, and FoodWIN, a Belgian NGO dedicated to tackle food waste (member of the EU’s Platform FLW), we strongly recommend that the Commission puts forward a legislative proposal for all member states to meet a 50% reduction of Food Loss and Waste, like…

Safe Food Advocacy Europe – SAFE welcomes the inclusion of the setting of food waste reduction targets in the objectives of the European Green Deal and the Farm to Fork Strategy, and the efforts shown by the European Commission to allow interested stakeholders to express their comments on the proposal to revise the Directive 2008/98/EC on waste.

Thank you for the opportunity to give feedback. As a collective of social and circular enterprises, and lead organisation in a EU's Interreg 2 Seas project 'Food surplus and Labour, the Valorisation of Underused Resources' (Flavour), we got/get a better idea of the amount of food loss and waste (FLW) on the ground.

October 2021 EUROPEN response to the roadmap consultation on Food waste reduction targets EUROPEN, the European Organization for Packaging and the Environment, supports the Farm to Fork Strategy’s commitment to introduce EU-level binding targets for food waste reduction. Food waste has significant negative environmental, social, and economic impacts.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

POSITION PAPER Brussels, October 2021 ACE reply to the European Commission inception impact assessment (IIA) consultation on food waste – reduction targets The Alliance f or Beverage Cartons and the Environment (ACE) and its members BillerudKorsnäs, Elopak, SIG Combibloc, Stora Enso and Tetra Pak, welcome the European Commission initiative to tackle food waste via regulatory action.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

NEPLUVI fully supports the input given by AVEC, the association representing the EU poultry meat sector and would like to stress the importance of value creation on all parts of the animal. Products suitable for human consumption should stay valued as such.

The Austrian food industry has for many years been active in the prevention of waste in production, such as purchasing controls, processing of different types of raw materials, avoiding overproduction and improving internal needs planning, staff training, self-marketing of returns, the distribution of food to social institutions or the sale of food unfit for human consumption as feed.

Filed in German · English published by the European Commission

As Chamber of Agriculture we welcome the initiative to reduce food waste. Looking at the figures estimated the amount of wasted resources through discarded food is enormous and achieving improvements pivotal. The over-arching principle should be to choose those methods and means which reach the envisaged goals as efficient, effective and quick as possible.

Brighton and Hove Food Partnership welcomes the Commission’s Roadmap and the opportunity to submit our response. As a partner of the ‘Food surplus and Labour, the Valorisation of Underused Resources’ (FLAVOUR) project funded by the EU’s Interreg 2 Seas Mers Zeeën 2014-2020 programme, we strongly recommend that the Commission models a 50% reduction of FLW (food loss and waste) for all EU member states under Step 2…

We greatly value food and every loss of it comes at a cost to the environment due to time and resources used in producing it. We believe that the 50 % food waste reduction target until 2030 target must be mandatory accross whole food chain. This ought to start with farms and end with consumers.

Groupe Carrefour Projet de réponse à la consultation de la Commission européenne : Lutte contre le gaspillage alimentaire. 28.10.21 La lutte contre le gaspillage alimentaire est un défi collectif et une priorité dans la démarche de responsabilité sociétale de Carrefour.

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)

Preferred options and suggested improvement: Scope: Option S1/S2: As FW occurs throughout the FSC, targets should cover the whole FSC by setting targets at each stage of the FSC (hence a merging of S1 and S2). This will allow public authorities to monitor food waste generation not only in quantitative terms but also sectorally, allowing for the identification of hotspots and targeted sectoral improvement measures.

211028 “Have your say” Input from Sweden Food Arena to European Commissions Food waste – reduction targets Below please find prioritized food waste reductions areas from the Innovation and Research Agenda from Sweden Food Arena.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Nomad Foods welcomes the opportunity to contribute to the Roadmap on Food Waste Reduction Targets. We are Europe’s leading frozen food company operating in 22 European markets, with 19 in every 20 products that we sell ranking either #1 or #2 in market share.

Contribution of the Czech Ministry of Agriculture to the public consultation on reducing food waste Following the European Green Deal and the Farm to Fork Strategy, an indicative target has been set to reduce food waste by 50 % at retail and consumer level by 2030. We consider the issue of food waste and its long-term solution to be important.

Filed in Czech · English published by the European Commission

Europatat is the European Potato Trade Association, comprising both national associations and individual companies involved in the trade of seed, ware and early potatoes throughout Europe. Its members include a wide range of traders (including breeders, distributors, storers, packers, importers and exporters) delivering seed potatoes to farmers, raw material to the food industry, and packed potatoes to the retailers…

The objective of halving (per capita) food waste in the retail and household sectors by 2030 (SDG 12.3) needs to be extended to all actors throughout the food supply chain, including agriculture, the food industry, catering, mass catering, etc. All actors have to assume their responsibility or be held accountable through legal instruments.

Filed in German · English published by the European Commission

The Primary Food Processors (PFP) Association is welcoming the efforts taken at EU level to improve the sustainability of the food supply chain, and the initiatives to assess and prevent food waste, including the possibility, foreseen in this Roadmap, to set up a Union-wide food waste reduction target to be met by 2030.

The European Federation of Corrugated Board Manufacturers (FEFCO) supports the objective of the present EU initiative in proposing food waste reduction targets as these will reduce the environmental impact of the EU food system and support the ambition of the EU Green Deal. Corrugated cardboard packaging has worked with the value chain for many years to provide fit for purpose packaging and prevent food waste.

The Plant Based Products Council (PBPC) appreciates the opportunity to provide input to this initial consultation on the proposed Policy Framework on biobased, biodegradable, and compostable plastics. PBPC represents businesses large and small in the United States and internationally, including the European Union, who are advocating for a shift toward a more circular bioeconomy through greater adoption of renewable…

BEUC, the European Consumer Organisation, welcomes the opportunity to comment on the inception impact assessment concerning the setting of binding targets for food waste reduction. Food waste has major environmental, ethical and economic impacts and must be addressed at systemic level – an undertaking towards which binding reduction targets can contribute.

Ecoteca NGO (Romania) strongly encourages setting binding targets committing to a 50% reduction by 2030 of all MS equally for food waste from farm to fork, and bring forward the proposal of binding targets on food waste to the whole supply chain (production and supply chain).

As members of the EU`s FLFW platform, we welcome the Commission´s initiative to propose EU-level targets for food waste reduction. Regarding the scope, we recommend adopting Option S1 to provide equal treatment for all stages of the supply chain and comprehensive coverage rather than limiting scope to cover retail and consumer sectors only. This is in accordance with guidance from Champions 12.3.

Mensa Cívica thanked for the opportunity to comment on this roadmap, which is part of the European Farm to Fork Strategy, and aims to propose legally binding targets to reduce food waste, thus creating a more sustainable food system.

Filed in Spanish · English published by the European Commission

Food waste constitutes a substantial proportion of municipal waste, in addition to the waste produced in production, processing and distribution. In landfills it is a source of the greenhouse gas methane, in waste incinerations it reduces energy recovery because of its high water content. Even more importantly, food wasted means a need to produce more food and food production has a huge environmental cost.

We welcome the Commission’s Roadmap and the opportunity to submit our response. As a member of the EU’s Platform FLW, we strongly recommend that the Commission models a 50% reduction of FLW (food loss and waste) for all EU member states under Step 2 Option 3 (rather than 40-50% reduction) and puts forward a legislative proposal for all member states to meet a 50% reduction of FLW from farm to fork by 2030, ideally…

Food waste is a phenomenon that needs to be tackled by eliminating the free disposal of surpluses by food businesses. To date, the value of the surplus food, whether cooked or packaged, is of less real and perceived value than littering, for which everyone contributes through Tari at least in Italy.

Filed in Italian · English published by the European Commission

Tetra Pak supports the EU Commission’s roadmap for food waste reduction targets to limit the food supply chain’s impact on the environment and climate while ensuring more food is available for human consumption.

APEAL contribution to Inception Impact Assessment, proposal for a revision of Directive 2008/98/EC on waste – part on food waste reduction target: In the Farm to Fork Strategy, the European Commission supports the use of “innovative and sustainable packaging solutions using environmentally-friendly, re-usable and recyclable materials”.

For the Pays de la Loire Region, the objective by 2025 is to reduce the prevention of household and similar waste by -80 kg/in./year compared to 2015 (see Energy Transition Act for Green Growth). The ¾ prevention target comes from the prevention of bio-waste, in particular by combating food waste.

Filed in French · English published by the European Commission

The European Environmental Bureau (EEB) welcomes the initiative to propose EU-level targets for food waste reduction. Firstly, we would like to remind that all Member States (MS) committed to achieve the SDGs by 2030, and in particular SDG 12.3 on food waste reduction as a minimum. This commitment has been recalled in the Farm to Fork Strategy (F2F Strategy).

Food waste is a missed opportunity to feed an ever-increasing global population, a major waste of resources and a needless source of increased emissions. As one of the world’s biggest food companies, Unilever clearly sees the role we have in protecting and preserving food to feed the world sustainably.

Confartigianato Imprese believes that a reduction in food waste and surpluses is of primary importance both for reasons related to the improvement of environmental sustainability and for what concerns the reduction of production costs faced by companies, those of micro, small and medium size.

The European Paper Packaging Alliance Proposal for a revision of Directive 2008/98/EC on waste – part on food waste reduction target Feedback on the inception impact assessment The European Paper Packaging Alliance (EPPA) welcomes the European Commission’s development of a proposal of EU-level targets for food waste reduction.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As an expert and researcher having worked on food waste for 10 years, I encourage the Commission to maintain a 50% reduction target of FLW (consistent with SDG 12.3) with a binding legislative framework. Step 2 Option 3 should therefore model a 50% reduction and not 40-50%. I recommend that member states could use a 2015 or later baseline based on available data.

ZERO – Association for the sustainability of the Earth System has been following the issue of food waste with great concern. We consider that the Farm to Fork strategy envisions a high level of ambition to this process and therefore we should make the 50% food loss and waste reduction target by 2030 (SDG 12.3) that was voted by all UN member states in 2015, binding at the EU level and matching the bloc’s ambition on…

Food waste is one of the solutions, that an individual can take action on and see immediate results in combating the climate crisis. Prevention is the priority when addressing food waste. We cannot scale prevention, less we create and share insights, long the food system. A uniform data standard is needed. And convincingly, that standard is ready working in Belgium.

Filed in Dutch · English published by the European Commission

From south-eastern Spain, SCRATS supports this objective in the regions of Alicante, Almería and Murcia, through proper management of water resources and adequate and sustainable management of agri-food production, vital to prevent food losses and waste during this production stage.

Filed in Spanish · English published by the European Commission

It is to note that food services are responsible for only 12% of the total food waste produced in the EU. In fact, hospitality represents only a small share of this percentage, as food services include sectors not covered by our sector (e.g. party catering; contract catering in hospitals, schools, public institutions). Therefore, our fair share of responsibility is limited.

French local authorities are preparing for the widespread sorting of food waste at source on 1 January 2024. Separate treatment of this waste is one of the few ways of reducing within a reasonable time and very significantly the still very large amounts of residual waste which, in the absence of prior sorting by the inhabitants, is incinerated or, in the worst case, buried.

Filed in French · English published by the European Commission

The inception impact assessment on the above subject, published by the Commission, has been reviewed, and the following opinion and proposal have been made in the course of the public consultation. As part of the European Green Deal, the European Commission adopted the “Farm to Fork strategy for a healthy and environment-friendly food system” in May 2020 to facilitate the transition to a healthy and sustainable…

Filed in Hungarian · English published by the European Commission

We, the Stop Wasting Food movement (Stop Spild Af Mad), as a member of the EU Platform of Food Losses and Food Waste, advise the European Commission for the “Proposal for a revision of Directive 2008/98/EC on waste - part on food waste reduction target” to focus more on the on the prevention of food waste rather than on reducing food waste.

While we know that the most important food waste occurs at household level - hence the need for a massive investment in public education - we also need to circularize as much as possible the food system to avoid wasting food. It should be compulsory that at each stage of the food system, a clear and auditable set of measures to fight food waste and to promote circularization as opposed to destruction should exist.