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.

The Swedish environmental company Ragn-Sells, active in waste management, environmental services and recycling, converts waste into raw materials that can be used over and over again. Ragn-Sells drives the transition to a circular economy through solutions that reduce the companys own and other actors' environmental and climate impact.

The environmental company Ragn-Sells converts waste into raw materials that can be used over and over again. Ragn-Sells drives the transition to a circular economy through solutions that reduce its own and other actors' environmental and climate impact. Ragn-Sells wants to be living proof that caring for the earth and business go hand in hand. Please find our response to this consultation attached.

Summary of Ragn-Sells view on the Commissions proposed revision of directive 2008/98/EC on waste Transitioning to a circular economy is crucial to our ability to mitigate climate change, the depletion of our natural resources, and the risk of overshooting planetary boundaries.

Ragn-Sells and scientists in Estonia have developed an innovative and patented technology to produce precipitated calcium carbonate (PCC) from oil shale ash and carbon dioxide two large waste streams. PCC made from oil shale ash can then be used to produce new products (flooring, paints, and other construction materials), reducing the demand for mining several virgin materials.

Ragn-Sells welcomes the Commissions review of the EU ETS. The scheme is a vital instrument to facilitate Europes reduction of CO2 emissions. A broadening of the EU ETS to the waste management sector would, however, need to be done with consideration of the sector's ability to produce key raw materials. Such development must not impose new barriers that risk slowing down or even preventing the circular transition.

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 Commissions proposal is an important step in the right direction, but unfortunately not enough. Wastewater and sewage sludge contain valuable raw materials, such as phosphorus and nitrogen, that are essential for food production.

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.