Ragn-Sells

Ragn-Sells is a family-owned Swedish waste management company, now evolving into a resource producer and detoxifier, focused on driving a future circular economy. Since 2015, we have transformed our approach around three guiding principles: reducing virgin resource use by delivering high-quality materials from urban flows, decontaminating all material flows, and protecting a liveable planet for future generations.

The Industrial Accelerator Act creates a strong demand pull for recycled materials, as products with a high share of recycled content are assigned a lower calculated climate impact. This means that industrial producers are encouraged to increase their use of secondary raw materials.

Ragn-Sells agrees with the Commission's ambitions for industrial decarbonisation. As today's energy-intensive industries are based on the current linear way of producing goods and services, we would, however, like to underline the need for circular solutions as a tool to accelerate decarbonisation. By developing new decarbonisation methods that only eliminate emissions, old linear ways of production will continue.

Ragn-Sells welcomes the Commissions initiative to extend the scope of CBAM to cover certain steel and aluminium-intensive downstream products. We agree with the Commissions assessment, as stated in its call for evidence, that downstream products may lead to increased carbon leakage if they are excluded from the CBAM scope.

Ragn-Sells welcomes the Commissions Call for Evidence on Biotech Act II. The issue of circular nutrient recovery from aquaculture side streams, however, highlights a broader systemic barrier affecting industrial biotechnology in Europe. Despite proven technologies, regulatory fragmentation across waste, animal by-product, fertiliser, and feed legislation continues to limit the scaling of biomanufacturing solutions.

Ragn-Sells welcomes the Commissions initiative to simplify the administrative burden in environmental legislation. We, however, urge the Commission to address the barriers illustrated in the examples below (see attached file for more information). Phosphorus from sewage sludge. Using recycled phosphorus from sewage and fish sludge would greatly contribute to a more resilient, competitive, and sustainable Europe.

The conclusion from the United Nations Framework Convention on Climate Changes (UNFCCC) outcome of the first global stocktake (Article 35, 55 and 63d) is clear we need to restore the health of our coastal areas.

The conclusion from the United Nations Framework Convention on Climate Changes (UNFCCC) outcome of the first global stocktake (Article 35, 55 and 63d) is clear we need to restore the health of our coastal areas.

Ragn-Sells innovations enable treatment plants to recover nitrogen from wastewater in solid form, which can be used immediately in the production of fertilisers. Our innovation company EasyMining has developed a technology (Aqua2N) that, compared to the old biological nitrogen removal method, reduces the greenhouse gas emissions at the wastewater treatment plants, removes the N2O emissions entirely and reduces the…

Ragn-Sells welcomes the EU-wide end-of-waste criteria for plastics. It will open the market to new actors that do not trade waste, create a more level playing field for recyclers, and address unfair competition from virgin materials. We are, however, concerned that these measures are too complex to enforce and take too long to implement. This applies in particular to the Quality Management System (QMS) in Article 5.

Ragn-Sells calls on the Commission to consider the following points. 1. Recognise secondary raw materials as a strategic pillar of EU raw materials security The European Critical Raw Materials Centre should explicitly recognise secondary raw materials as a core component of Europe's supply security strategy.

Ragn-Sells welcomes the Commissions proposed products, components and waste streams listed in the annexe. We want to emphasise the strategic importance of utilising the phosphorus recovery potential in sewage sludge. Today, the EU is almost entirely dependent on imports to supply its agriculture with phosphorus, one of the key ingredients in fertiliser and animal feed.

Ragn-Sells welcomes the Commissions delegated regulation on products derived from animal by-products as component materials in EU fertilising products. We do, however, regret the regulations limited scope. At present, it remains unclear whether fish sludge is classified as an animal by-product.