Detailed ESRG-Response = attached Only Summary / ESRG Proposal: In support of this sector to establish: 1. Mechanisms to see the waste hierarchy is better used, justified and enforced. 2. Harmonized end-of-waste criteria at EU level, like existing solutions, based on a study led by the Joint Research Centre, with contributions from the ESRG supporting the three mentioned elements
ESR
ESRG
Industry association · Belgium · EU Transparency Register 303140125180-29
5
positions filed
in the 665 files tracked
4
legislative files
of 665 tracked
3
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1106 non-governmental organisations on this site, they rank #303 by legislative files engaged, a count of participation, not a measure of influence.
0.2
declared lobbying FTE
self-declared
€25K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2016
in the register since
Declares membership of
- Cooperation with Hazardous Waste Europe (HWE)
- 92100 Boulogne
- France →
- (→ http://www.hazardouswasteeurope.eu)
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Non-governmental organisations
- Registered as
- European Solvent Recycler Group (ESRG)
- Head office
- Bruxelles, Belgium
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
ESRG filed 5 positions between 1 Jun 2021 and 6 Nov 2025, across 4 of the 665 legislative files tracked here, attaching a full position paper 3 times.
2021 · 3 filed2022 · 1 filed2025 · 1 filed
What they argued
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.
The European Solvent Recycler Gourp - ESRG - are supportive of the main aims of the proposals. In respect of the Circular Economy, ESRG would like to see updated Guidance offered to Member States in respect of managing standards for full recoveries derived from wastes and the use of exemptions to support both REACH and in turn CLP.
The European Solvent Recycling Group — ESRG — are supportive of the main aims of the proposals. In respect of the Circular Economy, ESRG would like to see updated guidance offered to Member States in respect of management standards for full coverage derived from wastes and the use of exemptions to support both REACH and in turn CLP.
Filed in German · English published by the European Commission
The Euroepan Solvent Recycler Group - ESRG - are supportive of the main aims of the proposals. In respect of the Circular Economy, ESRG would like to see updated Guidance offered to Member States in respect of managing standards for full recoveries derived from wastes and the use of exemptions to support both REACH and in turn CLP. B. Freitag ESRG-Secretariat
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.