FEAD - European Waste Management Association

FEAD, the European Waste Management Association, represents the entire waste and resource recovery sector in Europe, including collection, sorting, recycling, energy and material recovery, and the final disposal.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the revision of the public procurement directives in the EU. With the aim of improving competition and the circular economy, we present a number of critical remarks on the functioning of public procurement in the waste management market.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the initiative to strengthen the European manufacturing industry. However, the focus of the Industrial Accelerator Act remains on primary production industries, not considering recycled materials as equals. This sends a regrettable signal.

FEAD strongly welcomes the proposal in the call for evidence for the upcoming Industrial Decarbonisation Accelerator Act to assess incentives for uptake of clean carbon feedstock, including recycled waste and recovered energy. The geopolitical climate, disruptions to global supply chains, and increasing competition for critical inputs have exposed Europes dependence on finite resources.

FEAD welcomes the European Commission’s proposal for reviewing the 2018 Renewable Energy Directive (REDIII) and adjusting its rules to the latest EU climate ambitions for 2030. Therein, FEAD supports the unchanged definition of ‘waste heat’, considering that the activities of hazardous and non-hazardous waste installations are producing waste heat, when recovered by efficient district heating and cooling systems.

Please, find attached FEAD’s full feedback to the EC Roadmap on the Revision of REDII. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative to review the 2018 Renewable Energy Directive (REDII).

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the evaluation of the public procurement directives in the EU. With the aim of improving competition and the circular economy, we present a number of critical remarks on the functioning of public procurement in the waste management market.

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe, welcomes the Commissions legislative proposal on Packaging and Packaging Waste, as it reaffirms recycling as the core element of circularity.

Please, find attached FEAD’s full feedback to the EC Roadmap on Packaging Waste. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the EC initiative on the review of the requirements for packaging and on other measures to prevent packaging waste and considers it of the utmost importance in achieving a…

FEAD welcomes the Commissions proposal for a Critical Raw Materials Regulation (CRM) as an important step towards clearly acknowledging the role of circularity, recycling and recovering of materials in the diversification of supply sources and in reducing the EUs dependencies. In addition, by recycling CRMs, the EU can conserve natural resources, and minimise the environmental impacts of mining and extraction.

The coronavirus pandemic and its economic aftermath along with the current energy crisis resulting from EUs dependency on Russian fossil fuels have only increased the urgency to ensure the security of supply of raw materials to the EU and its strategical independence, as well as to reduce the impacts on the environment due to increased use of CRM in the global economy.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the European Commissions proposal for a Regulation establishing the European Competitiveness Fund (ECF).

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.

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.

FEAD welcomes the development of EU rules for the certification of carbon removals to support the achievement of the EU climate targets. To reach climate neutrality by 2050, carbon capture, utilisation and storage (CCUS) and carbon recycling solutions are needed.

A full inclusion of MWI installations in the EU ETS without any complementing additional measures is not suitable to achieve emission reductions in the waste management sector. WtE has hard-to-abate emissions that cannot proactively be mitigated by the operators in any other way than with carbon captures. Without this, the only way to reduce emissions would be to shut down facilities or rejecting certain wastes.

FEAD, the European Federation for Waste Management and Environmental Services, welcomes the European Commission’s initiative to substantiate green claims in order to empower the consumer and business partners for the green transition. Private waste management companies are major operators in this service, operating in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste.

FEAD fully supports the Commission’s Sustainable Products Initiative and its main objectives of reducing the negative life cycle environmental impacts of products, and the improvement of the internal market through a harmonised ecodesign approach.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative on sustainable products under the European Green Deal and the new Circular Economy Action Plan (CEAP).

As previously exposed, FEAD welcomes the European Commission’s proposal for a carbon border adjustment mechanism (CBAM) as a complementary tool to the EU ETS and the overall EU environmental legislation, to counteract the risk of carbon leakage. In principle, EU regulations aimed at making the economy more circular constitute increased costs along the whole product life cycle.

FEAD – the European Federation for Waste Management and Environmental Services, supporting and promoting circular economy in the EU, is in favour of a carbon border adjustment mechanism (CBAM), as complementary to the EU ETS and the overall EU environmental legislation.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission. As previously stated, FEAD welcomes the legislative package proposed, which delivers the crucially needed changes to achieve a fair, competitive and green transformation.

Please, find attached FEAD’s full feedback to the EC Roadmap on the Revision of EED. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative to review the 2012/27/EU Energy Efficiency Directive (EED).

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission.

Please, find attached FEAD’s full feedback to the EC Roadmap on updating the EU ETS. FEAD, the European Waste Management Association, represents the private waste and resource management industry across Europe. Private waste management companies operate in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste.

FEAD welcomes the Commission’s proposal for a new Construction Products Regulation and its main objectives of achieving a well-functioning single market for construction products and contributing to the goals of the green and digital transition. The European Waste Management Industry gives a strong contribution in the transition to a circular economy of the construction products sector.

Please, find attached FEAD’s full feedback to the EC Roadmap on the Review of the CPR. FEAD, representing the private waste and resource management industry across Europe, welcomes the European Commission’s initiative to review the Construction Products Regulation (CPR).

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Revision of EU legislation on hazard classification, labelling and packaging of chemicals which aims at protecting people and the environment better against hazardous chemicals and at encouraging innovation for the development of safer alternatives.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission. As previously stated, FEAD welcomes the legislative package proposed, which delivers the crucially needed changes to achieve a fair, competitive and green transformation.

FEAD, the European Federation for private waste and resource management, supports the revision of the Energy Taxation Directive (ETD), as one of the instruments of the European Green Deal. A well-designed ETD should work together with the Circular Economy Action Plan and boost the circular economy in Europe.

FEAD, the European Waste Management Association, representing the private waste management industries in Europe, welcomes the possibility to respond to this valuable initiative promoted by the European Commission on shaping the renewable energy legal framework.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to provide feedback on the evaluation of the Single-Use Plastics Directive (SUPD).

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.

FEAD does not call for a revision of the IED (Industrial Emissions Directive), and is convinced that climate ambitions, as well as circular economy benefits, should be addressed elsewhere. IED’s philosophy relies on site specific permitting. It is not suited for an overarching approach.

FEAD welcomes the proposal. Our main comments to it: -Lack of a mandatory deposit refund system Incorrectly disposed Li batteries pose a high risk to people and the environment. It is necessary to return 100% Li batteries from a wide variety of waste streams to the battery collection.This can only be achieved through a mandatory return for particularly critical material flows, in addition to a high collection rate…

FEAD welcomes the EU initiative of modernizing the EU rules on Batteries in line with the Green Deal and other sustainability-related policies like the new CEAP. From a waste management perspective, in order to improve the circular economy which requires more and more ambitious targets in terms of quantity and quality, we would like to stress the following needs: • Update and harmonization of definitions It is…

FEAD position on the environment omnibus I. FEAD calls for maintaining the national authorised representative requirement The Authorised Representative (AR) is a central element of effective EPR enforcement—not a mere administrative formality.

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

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Commissions Proposal for a Regulation on end-of-life vehicles (ELVs Regulation) as part of the new Circular Economy Action Plan (CEAP) and the European Green Deal.

FEAD, the European Federation for Waste Management and Environmental Services, welcomes the Revision of Directive 2000/53/EC on End-of-Life Vehicles as part of the new CEAP and the Green Deal. Historically, the vehicle composition is changed and is shifted towards light materials such aluminum and polymeric constituents to make the vehicles lighter and therefore less energy consuming and less polluting.

FEAD, representing the European private waste and resource management industry, supports an ambitious CBAM as a crucial tool to reinforce the competitiveness of EU industry, and contribute to achieving the Unions climate and circular economy objectives. Recycling in the EU, in particular plastics recycling, is currently under significant economic pressure.

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals which aims at protecting people and the environment with regard to hazardous chemicals, and at encouraging innovation for the development of safer…

FEAD, the European Waste Management Association, welcomes the European Commissions initiative to reinforce the EUs climate resilience and risk management framework. With members operating across the entire waste value chain, we represent a sector that is both critical to continuity of essential services and instrumental in ensuring environmental safety in case of extreme weather events.

FEAD welcomes the Commissions work to establish the Digital Product Passport (DPP) Registry under Regulation (EU) 2024/1781. The DPP can become an important tool to improve transparency across value chains, support safer treatment and recycling, and facilitate the transition to a circular economy.

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe supports the Commissions Proposal for a Regulation to prevent plastic pellet losses and to reduce microplastic pollution as a supportive tool to reach the objectives of the European Green Deal and to reinforce overarching strategies such as the Plastics…

The undersigned organisations, representing civil society, business organisations and companies active along the waste management value chain, highlight that rules for calculating recycled content in plastics using a mass balance approach under the Single Use Plastics Directive (SUPD) will in influence market dynamics and shape the industry for decades to come.

FEAD welcomes the European Commissions intentions on the sustainability criteria for plastic recycling technologies under Article 7(9) of the Packaging and Packaging Waste Regulation. This contribution focuses exclusively on the future delegated act establishing those criteria.

FEAD, the European Waste Management Association representing the private waste and resource management industry across Europe, welcomes the upcoming secondary legislation under Article 7 PPWR on the calculation and verification of recycled content.

FEAD, the European Waste Management Association, welcomes the European Commission's proposal for the Digital Product Passport (DPP) under the Ecodesign for Sustainable Products Regulation. As representatives of the waste management private sector, we recognise the DPP as a key tool to promote transparency across product value chains, support sustainability objectives and enable the transition to a circular economy.

FEAD, the European Waste Management Association, welcomes the European Commissions initiative to develop an Advanced Materials Act. Advanced materials will play a central role in decarbonisation, clean technologies and strategic value chains. At the same time, they are already creating new and increasingly complex waste streams that challenge existing collection, sorting, treatment and recycling systems.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the possibility to provide feedback on the proposed revision of the Waste Shipment Regulation (WSR).

Exports are crucial for a well-functioning EU waste market. FEAD underlines that WSR is and must remain a regulation used for shipment procedures and must not become a policy instrument for new objectives. While it must be consistent with the objectives of the Circular Economy, its adaptation must not be detrimental to safety nor traceability and must ensure that formalities are appropriate regarding the…

FEAD, the European Waste Management Association, appreciates the opportunity to comment on the application of the do no significant harm (DNSH) principle in the next multiannual financial framework (MFF). FEAD welcomes that the call for evidence clarifies that the DNSH principle under the Taxonomy and the next MFF have different legal basis, objectives, scope and design features.

FEAD, the European Waste Management Association representing the private waste and resource management industry across Europe, welcomes the Commissions proposal revision of the Urban Wastewater Treatment Directive, to bring the objectives of the Directive adopted in 1991 up to date.

FEAD, the European Waste Management Association, welcomes the review of RED Annexes V and VI and thanks the Commission for the opportunity to comment. FEAD puts forward the following recommendations: The introduction of an equivalent negative emission credit for biowaste as to what is currently granted to manure Clarifying what are standard and best practices in view of defining GHG emission saving values Updating…

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Commissions latest Directive to amend the Council Directive 91/676/EEC on specific fertilizing materials from livestock manure.

FEAD, the European Waste Management Association, is deeply concerned about the EUs initiative to regulate the aluminium scrap market and calls upon the European Commission to focus on the competitiveness of the entire aluminium value chain. Market restrictions on recycled materials impact our sector as export restrictions would impact any other industry.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the Commissions efforts to establish EU-wide end-of-waste (EoW) criteria for plastic waste under Article 6 of the Waste Framework Directive.

FEAD, the European Waste Management Association, call for the Implementing Act on the mirror clause to include a European prioritisation with the introduction of a clear Made in Europe preference for plastic recycled content (RC) targets. FEAD calls on the European Commission to ensure that the future Implementing Act is built around the following three key principles: 1.

Please, find attached FEAD’s full feedback to the EC Roadmap on Empowering the Consumer for the Green Transition FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative to empower the consumer for the green transition.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the Commission´s initiative for green-listing WEEE and other waste streams. Technical comments are made to individual entries in the file attached.

FEAD welcomes the possibility to contribute to the EU climate policy framework after 2030 and emphasises the importance of incorporating in this framework the promotion of the circular economy a key element currently absent from the call for evidence. When the Commission published its Communication on the 2040 climate target it emphasised the significance of the circular economy to achieve the EUs climate goals.

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe has taken notice of the Commissions Delegated Regulation on extending the scope of the data to be included in the Union Database (UDB) as it can potentially be an important tool for increased transparency under the Renewable Energy Directive (RED).

FEAD supports the revision of EU rules on textile labelling to ensure the correct information of consumers. The waste management sector needs information on the waste received, but a label at product level will have little added value for waste managers working with big and bulky flows and applying automatic (sorting) processes.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, would like to comment on Annex I, the format for the disclosure of information on discarded unsold consumer products.

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the Commissions efforts to harmonise battery labelling requirements under Article 13 of Regulation (EU) 2023/1542.

The Guidelines give a list of requirements which specify a 'common interest' under section 3.1. The criteria mentioned are of social nature and related to market failures. However, to enable the implementation of the Clean Industrial Deal, this common interest urgently has to be updated with sustainability criteria.

FEAD, the European Waste Management Association, welcomes the Commission's draft Delegated Act regarding the list of waste streams with high critical raw material recovery potential under Article 26 of the Critical Raw Materials Act (CRMA).

The Commission has proposed amendments to Annexes IV and V to Regulation (EU) 2019/1021 of the European Parliament and of the Council on persistent organic pollutants. This initiative intends to update, for certain substances and groups of substances, the concentration limits set in Annexes IV and V of the POPs Regulation, which determine how waste containing POPs is treated, and particularly if it can be recycled…

FEAD, the European Federation for Waste Management and Environmental Services, welcomes amendments to the annexes of Regulation (EU) 2019/1021 on POPs, aiming to achieve a toxic-free environment. FEAD believes that addressing and revising new values for different substances is crucial in order to limit the presence of certain POP substances in waste and in material that could be recovered through it.

FEAD, the European Waste Management Association, welcomes that the proposal maintains full flexibility for Waste-to-Energy (WtE) operators to either apply a calculation-based or a measurement-based methodology. Nevertheless, FEAD notes a number of points in relation to the draft Implementing Regulation amending Commission Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas…

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the revision of the Industrial pollution – European Pollutant Release and Transfer Register as an initiative part of the European Green Deal, the new Circular Economy Action Plan and the recently published Commission Staff Working Document Evaluation of…

FEAD welcomes the publication of the EC Roadmap "Towards an EU Product Policy Framework". The private waste and resources management industry would like to stress the following points: • We need to focus more on the very first step in the value chain and intensify our cooperation with designers and manufacturers to ensure that products are designed to prevent waste and to be easily reused, dismantled and recycled.

FEAD, the European Waste Management Association representing the private waste management industry in Europe, as well as the European Cylinder Makers Association (ECMA) and the Confederation of European Waste-to-Energy Plants (CEWEP), welcome the European Commissions proposal for a REACH restriction on nitrous oxide (NO).

Please, find FEAD’s full feedback attached. FEAD, the European Waste Management Association, represents the private waste and resource management industry across Europe. FEAD welcomes the European Commission’s proposal for a Decision for the 8th Environment Action Programme (EAP).

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to provide feedback on the draft Delegated Act establishing rules for the calculation and verification of average loss rates (ALR) for the sorting of waste under the Waste Framework Directive.

FEAD, the European Waste Management Association, welcomes the proposal of the European Commission to propose an unintentional trace contaminant (UTC) limit value for Polychlorinated biphenyls (PCBs) under the Annex I of the POP Regulation.