HAZARDOUS WASTE EUROPE

HWE feedback Circular Economy and Hazardous Waste 1/ Not all hazardous waste is recyclable, and the treatment is determined by the characteristics of the waste. HWE welcomes this consultation and emphasizes the need to take into account the specific nature of hazardous waste streams in terms of circularity.

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

Hazardous Waste Europe (HWE) welcomes the planned revision of the Directive 2018/2001 and specifically measures aiming to promote a better use of recycled carbon fuel in maritime transport. A significant part of hazardous waste are carbon-based waste and part of it contains fuels that can be separated and purified in order to produce marine fuel.

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).

Hazardous Waste Europe input to the consultation on the review of ETS 1 Hazardous waste represents a relatively small amount - less than 5% of the total volume of waste produced each year. The purpose of hazardous waste incineration is to protect human health and the environment by destroying the hazardous waste generated by economic activities.

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

Non toxic material cycles are key to ensure a clean and sustainable circular economy to create confidence in secondary raw materials. This happens by implementing safe and sustainable by-design requirements, but also by taking into account a few principles at the recycling phases.

Hazardous Waste Europe (HWE) is a European wide association whose members operate all the diversity of hazardous waste treatments from recycling to final disposal including dedicated hazardous waste incineration. HWE recognizes and endorses the urgent necessity to bring more efforts for achieving the targets of the Paris agreement and specifically the EU commitment for carbon neutrality in 2050.

Classification is a key challenge of the interface between waste, chemicals and products. It is one of the main tools that will pave the way to the EU Green Deal objective of a zero pollution ambition for a non-toxic environment.

Filed in French · English published by the European Commission

Hazardous Waste Europe (HWE) welcomes the planned revision of the ETD and its related roadmap. In the light of the problems the initiative aims to tackle, Hazardous Waste Europe (HWE) would like to emphasize the need for clarifications in ETD in order not to undermine the role of the hazardous waste sector.

Hazardous waste accounts for relatively small volumesless than 5% of the total waste generated each yearbut must meet strict criteria for hazardousness. For example, it may be carcinogenic, mutagenic, or toxic to reproduction.

The Industrial Emission Directive (IED) is a cornerstone of the EU legislation, aiming at achieving a high level of protection of the environment as a whole. The EU Commission’s proposal for a revision of the IED provides valuable and key provisions to prevent and control pollution arising from industrial activities and issue environmental permits.

The Industrial Emission Directive 2010/75 has demonstrated efficiency to provide an EU framework to “reduce emissions into air, water and land and to prevent the generation of waste, in order to achieve a high level of protection of the environment taken as a whole”. As an active partner since the beginning in the valuable Sevilla process - including IED article 13 Forum, HWE is familiar with the IED directive.

HWE welcomes the objectives seeked by the Commission’ s proposal for a regulation concerning batteries and waste batteries to reach competitiveness, circularity and protection of health and the environment. As such, the current proposal is part of the EU Green Deal, by striving to conciliate functioning of the internal market and a zero pollution ambition for a toxic- free environment.

As a federation representing hazardous waste operators present on the whole chain, from collection to final treatment, ELVs are not directly our core business. Nonetheless, our commitment to ensure non toxic material cycles and limit the dispersion of pollutants in the environment grant us some legitimacy to share our key principles to reach the zero pollution ambition for a toxic-free environment called by the EU…

The revision of the REACH regulation is at the core of the interface of waste, chemicals, and products legislation. The interface is key to ensure the zero pollution ambition for a toxic free environment. The Reach regulation represents a significant cornerstone of the chemicals strategy for sustainability and an important piece of legislation to deliver the objective of the EU green deal.

Hazardous Waste Europe (HWE) welcomes the European Commission’s proposal for the revision of the Waste Shipment Regulation (WSR). We are very pleased to see that most of the main issues raised by HWE have been addressed with concrete and appropriate proposals: -adaptation of the amount of waste in case of experimental treatment trials, -clarification of the timing and deadlines regarding the requests for…

Based on the Commission's SWD evaluating the WSR and on the information provided through the IIA, HWE wants to share views on the Commission's understanding of the different problems pointed out. As a preliminary statement, we would like to insist on the fact that the WSR is an adequate piece of legislation at the EU level to ensure safe shipments of waste, traceability and to guarantee appropriate treatment of…

As a federation representing hazardous waste operators present on the whole chain, from collection to final treatment, urban waste water treatment (UWWT) is not directly our core business. Nonetheless, our commitment to ensure non toxic material cycles and limit the dispersion of pollutants in the environment grant us some legitimacy to share our key principles to reach the zero pollution ambition for a toxic-free…

Hazardous Waste Europe (HWE) welcomes the Commission proposals amending the WFD, EQSD and GWD. We specifically support the effort of harmonisation and coherence between the 3 texts. It should now continue with other related texts under revision and particularly the UWWTD, SSD, IED and IEPR.

Hazardous Waste Europe would like to acknowledge the huge and serious work carried out by the EU Commission which supports this proposal for amending annexes IV and V to the POP Regulation. HWE fully endorses the rationale behind the proposal. Lowering the annex IV values for a series of POP substances is a powerful and coherent means to align with the ambition for a zero pollution in a non-toxic environment.

POPs are detrimental to health and the environment. They are chemicals that could end up in the recycling loops, once products become waste. Delivering the zero pollution ambition for a toxic-free environment wished by the Commission will require POP (and other substances of concern) identification, tracking and appropriate treatment to ensure non toxic material cycles and avoid dispersion into the environment.

Hazardous Waste Europe welcomes the objectives of the Inception Impact Assessment. Regarding the phasing-out of the use of dental amalgam, the timetable must be clear in order to: 1-ensure that each Member States will have time to shape the right solutions in order to take care of the lower-income part of the population who can't access today to alternative solutions to dental amalgam, 2-ensure that there will be no…

First of all, HWE would like to underline the usefulness of the E-PRTR. There is a great merit for all parties in having a EU wide system for reporting pollutants emissions and waste generation. Yet, as suggested by the IAA of the Commission, there are areas for improvements, e.g.

Hazardous Waste Europe represents hazardous waste operators present in the whole value chain of hazardous waste management, from collection to final treatment. Our operators are also present on port reception facilities to provide collection, recovery - when possible - and final treatment to all Marpol Waste Annexes.