European Recycling Industries' Confederation (EuRIC)

Circularity is no longer a niche environmental ambition - it is fast becoming a defining pillar of Europes industrial strategy. Amid mounting geopolitical pressures, volatile supply chains, and climate emergencies, the ability to retain materials, reduce resource dependence, and lower emissions has moved to the core of EU policymaking.

Public procurement represents a powerful yet underutilised tool in the EUs transition towards a climate-neutral, circular economy. Accounting for approximately 14% of the EU GDP - over 2.4 trillion annually, public procurement holds significant potential to influence market demand, shift production patterns, and accelerate the uptake of recycled materials and circular products, thereby contributing to the EUs…

Recycling Europe welcomes the Commissions objective to strengthen the EU industry and to stimulate demand for low-carbon products through the creation of lead markets under the Industrial Accelerator Act (IAA). Incentivising circularity and recycling is a key tool to reach these objectives.

The European Recycling Industries' Confederation (EuRIC) welcomes the forthcoming Industrial Decarbonization Accelerator Act as a key initiative to support the decarbonization of Europes energy-intensive industries, while maintaining their competitiveness and fostering innovation.

The implementation of mandatory measures in public procurement rules is crucial for stimulating the demand for recycled materials and contributing to the EU's decarbonization objectives. Impacting a multitude of streams covered by EuRIC members, public procurement holds a significant leverage for enhancing circularity within the EU Single Market.

The European Recycling Industry welcomes the ECs proposal for the new Regulation on Packaging and Packaging Waste [COM (2022) 677] and acknowledges the Commissions commitment to set ambitious measures to boost packaging circularity.

The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the Inception Impact Assessment on the review of the requirements for packaging and other measures to prevent packaging waste and fully supports the initiative’s aim to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin feedstock.

Directing investments towards a climate-resilient and net-zero economy by focusing on six environmental objectives, the EU Taxonomy is a cornerstone of the EUs sustainability strategy. Recycling Europe strongly supports this simplification initiative, while emphasizing it must not undermine the environmental ambition of EU legislation.

The European Recycling Industry welcomes the European Commissions (EC) proposal for a Regulation on Critical Raw Materials and acknowledges the Commissions commitment to set ambitious measures to boost the circularity of CRMs, which are often indispensable inputs for a wide set of strategic sectors including renewable energy. EuRIC represents the European recycling industry at an EU level.

The European Recycling Industries Confederation (EuRIC) welcomes the European Commissions initiative on Critical Raw Materials (CRMs) and is pleased to share the view of European Recyclers about what is needed at an EU level to achieve the very goals of it. EuRIC is the authoritative voice of the recycling industry at a European level.

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.

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.

The European Recycling Industries’ Confederation (EuRIC) represents the recycling industry at a European level. Gathering the vast majority of national recycling federations from EU/EEA Member States, the Confederation represents about 5.500+ recycling companies – from market leaders to SMEs – generating an aggregated annual turnover of about 95 billion € by treating various waste streams such as household or…

EuRIC welcomes the publication of the proposal for a Green Claims Directive as a positive step towards promoting transparent and accurate environmental claims in the European market. By setting clear guidelines and standards for eco-labelling, this initiative can help consumers make more informed and sustainable purchasing decisions, while also encouraging businesses to adopt more eco-friendly practices.

EuRIC strongly welcomes the publication of the proposal for a Regulation on Ecodesign for Sustainable products (2022/0095 (COD)) accompanied by the Communication on making sustainable products the norm (COM (2022) 140 final). Eco-design for recycling is a pre-condition to move towards a more circular economy.

The European Recycling Industries' Confederation (EuRIC), representing the interests of the European recycling industries, welcomes the Commission's ambitious Sustainable Products Legislative Initiative to connect the dots between the design and the end-of-life (EoL) phase of products, be them products having a short a long lifespan.

The European Recycling Industries Confederation (EuRIC) calls for a robust and future-oriented implementation of CBAM that closes current loopholes, supports genuinely low-carbon production methods, and ensures fair competition for recycled materials and EU industries. Please find our detailed feedback attached.

The European Recycling Industries’ Confederation – EuRIC AISBL – is an umbrella organization for the recycling industries in Europe. Through its Member Recycling Federations from 20 EU and EFTA countries, EuRIC represents over 5,500 companies, both large companies and SMEs, involved in the recycling and trade of various resource streams; EuRIC welcomes the public consultation on the draft 10th ATP regulation, and…

Directing investments towards a climate-resilient and net-zero economy by focusing on six environmental objectives, the EU Taxonomy is a cornerstone of the EUs sustainability strategy. Recycling Europe strongly supports this simplification initiative, while emphasizing it must not undermine the environmental ambition of EU legislation.

In this paper, Recycling Europe sets out a series of recommendations to strengthen the implementation of the Single-Use Plastics Directive (SUPD) and to support forthcoming legislation aimed at advancing the circular economy for plastics: Strengthen 2030 PET Targets: Increase the mandatory recycled content in PET bottles to 50% rPET to accelerate the transition towards a circular plastics economy.

The European Recycling Industries’ Confederation – EuRIC - welcomes the publication of an Inception Impact Assessment (IIA) within the framework of the revision of the Industrial Emission Directive. Looking at the different objectives and policy options detailed in it, EuRIC wishes to make the following comments. - BREF Process EuRIC agrees that options to improve the BREF elaboration process have to be explored.

The European Recycling Industries’ Confederation (EuRIC) welcomes the long-awaited proposed Batteries and Waste Batteries Regulation published by the EU Commission on December 10, 2020. It is a fact that improving the design of batteries – making them more sustainable, readily removable and easily recyclable - is a pre-condition to transition towards a circular economy.

Recycling Europe welcomes the Environmental Omnibus and the Commissions objective to facilitate the implementation of existing laws and the achievement of environmental objectives, while simultaneously reducing unnecessary bureaucracy and strengthening the Single Market.

EuRIC strongly welcomes the Inception Impact Assessment on the revision of Directive 2000/53/EC on end-of-life vehicles (ELVD) and its main objectives to increase the contribution of the automotive sector to the circular economy and to ensure that the ELVD is adapted to the current and future challenges faced by this sector.

The European Recycling Industries Confederation (EuRIC) is pleased to share the views of the recycling industry about the proposed Net Zero Industry Act1 which was published on 16 March 2023. EuRIC represents the recycling industry at a European level.

The European Recycling Industries’ Confederation (EuRIC) welcomes the Inception Impact Assessment on the revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) and its main objective to transition towards a clean Circular Economy.

EuRIC - the European Recycling Industries Confederation - believes that developing robust and fair calculation methods for the recycled content is of paramount importance to ensure a level playing field for all recycling technologies.

The sustainability criteria should consider the origin of recycled plastics, but also the environmental impact of recycling technologies used, as stressed in Art. 7(9) PPWR. The criteria should enable a robust differentiation between recycling technologies according to their overall environmental performance.

Recycling Europe recommends that the future Implementing Act under Article 7(8) of the PPWR is built around the following principles (further details in attachment): 1) Replicate under PPWR the mass balance calculation methodology agreed under the recently adopted SUPD Implementing Decision.

The European Recycling Industries Confederation (EuRIC) welcomes the opportunity to give feedback on the future delegated act laying down rules on the operation of the Digital Product Passport (DPP) and the role of service providers. Overall, EuRIC considers the DPP as a good opportunity for advancing recycling and the circular economy.

EuRIC thanks the European Commission for publishing the recent proposed revision of the Waste Shipment Regulation (WSR). EuRIC strongly supports the key objectives of the legislative revision however would like to express its grave concern on the consequences of the proposed measures on the EU’s recycling industry. This is described below.

EuRIC, the European Recycling Industries’ Confederation, strongly agrees with several issues arising from the Waste Shipment Regulation (WSR) that need to be tackled as indicated by the Impact Assessment. We, for instance, appreciate the emphasis put on the facts that the procedures are still mainly paper-based, there is no harmonization of interpretations of WSR provisions and procedures in different Member States…

Recycling Europe welcomes the opportunity to provide feedback on the Call for Evidence on trade measures aimed at ensuring sufficient availability of aluminium scrap on the EU market. However, the underlying assumption that the EU is facing a structural shortage or leakage of aluminium scrap is not supported by market evidence.

The European plastic recycling market continues to struggle, as recycled polymer demand remains weak with no signs of improvement. The recent package announced by the European Commission on 23 December, aimed at accelerating the EUs transition to a circular plastics economy, marks an important first step toward strengthening plastic recycling in Europe.

Recycling Europe recommends that the future Implementing Act under Article 7(10) PPWR is built around the following three key principles (for more details, see the attached FEAD-Plastic Recyclers Europe-Recycling Europe Joint Proposal for a Mirror Clause under PPWR): 1) Require Made in Europe recyclates for packaging produced or filled in the EU: In that case, compliance with recycled content (RC) targets should…

Recycling Europe welcomes the Commissions proposed delegated acts to facilitate intra-EU shipments of non-hazardous waste for recycling. The new green-list entries are an important step towards reducing unnecessary administrative burdens, improving legal certainty and supporting access to appropriate recycling capacity across the EU.

Securing access to Critical Raw Materials (CRM) is crucial to strengthening Europes resilience and competitiveness. The creation of the CRM-Centre (CRM-C) is therefore a step in the right direction. This new EU body could help create demand for recycled materials, a much-needed element to scale recycling capacities in Europe. But for this, the CRM-C must be fit for recycled CRM by design.

Recycling Europe, the voice of Europe's recyclers, supports the development of ecodesign requirements for iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR), recognising their potential to accelerate both decarbonisation and circularity across the steel value chain.

Representing the vast majority of critical raw materials (CRMs) and e-waste recycling facilities in Europe through its members, the European Recycling Industries Confederation (EuRIC) has a strong interest in supporting the identification of waste streams with high potential for CRM recovery to increase the volume of processed materials.

The rules for the calculation and verification of recycled content in batteries can play in important role in stimulating demand for recycled materials sourced within the EU, and strengthening the EU market for recycled materials, while enabling brands to make credible recycled content claims.

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of the proposed Regulation on persistent organic pollutants (POPs) which contains – in Annex IV & V - the updated concentration limit values of POPs in waste.

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of an Inception Impact Assessment for the revision of the applicable concentration limit values of persistent organic pollutants (POP) in waste. The necessary phase out of POPs, and the associated review of limit values, is rightfully backed here by an ongoing study taking into account socio-economic parameters.

The European Recycling Industries' Confederation - EuRIC - represents Authorised Treatment Facilities (ATFs) and the vast majority of ELV recycling facilities (shredders and post-shredder installations) which recycle ELVs in Europe.

The Ship Recycling Group of Recycling Europe welcomes the opportunity to provide feedback on the 16th edition of the European List of ship recycling facilities. The process of adding and removing yards from the EU List should ensure a level playing field across the sector and uphold high standards for ship recycling. This is, however, not reflected in the draft 16th EU List.

The European Recyclers’ Industry Confederation (EuRIC) welcomes this draft Implementing Decision regarding the calculation, verification and reporting of data on the separate collection of waste single-use plastic beverage bottles. Unfortunately we received notice of this consultation late and have not had time to properly consult our membership.

The formulations for polyurethane One Component Foams (OCF) may contain Medium Chain Chlorinated Paraffins (MCCP) to leverage their properties as plasticizers and their increased flame retardancy. As these substances are phased out, the treatment of the prepolymer remaining after use of the OCF containers will leave the recycling industry with two treatment options: recycling of these materials or incineration of…

Improving the design of products is a pre-condition to transition towards a circular economy. As it has already been highlighted in the report released by the European Recycling Industries’ Confederation (EuRIC) named “Top 5 Priorities of the Recycling Industry for the Period 2019 -2024”, 80% of products’ environmental impact are determined at a design stage.

The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the proposal - published by the EU Commission on April 8, 2022 - for a Regulation on substances that deplete the ozone layer. Ozone depleting substances (ODS) have depleted throughout the years the stratospheric ozone layer which has led to an increased solar UV-B radiation at the surface of the Earth (Norval et. all, 2011).