Ceepackaging

Environment

EUROPEN opposing EU on waste proposals

EUROPEN is strongly opposed
to proposals for a rigid “fivestep”
waste hierarchy which are
contained in a draft report,
scheduled for vote in the
European Parliament before
the end of this year. Under the
proposals, any derogation from
such a hierarchy would require
individual justification.

If adopted into law, EUROPEN
and other industry organisations
believe these proposals would be
unworkable in practice, would be
in opposition to fundamental
principles of EU law and would
not bring any additional
environmental benefits.
Many industry groups are
increasingly concerned that this
complex topic has been
misunderstood by some and its
importance as a critical element
of achieving sustainability goals
has been overestimated.
Fundamental principles of law
appear to have been
overlooked, such as the
necessity of proportionality and
equal treatment, without which
barriers to trade and distortions
of competition often appear.
The now generally applicable
‘Better Regulation’ tests commit
both the EU and Member States
to apply the triple impact
assessment: economic, social
and environmental. A strict
hierarchy is unlikely to be
justified under such tests.
In addition, much of the
discussion in relation to the
waste hierarchy remains
subjective and lacks objective
scientific justification.
No scientific evidence has thus
far established a strict hierarchy
between reuse, recycling and
other recovery options.
And numerous well-founded
studies consistently show that
the choice depends critically on
the particular circumstances
relating to a product chain.
EUROPEN continues to support
the Commission’s proposal for
a revised Waste Framework
Directive and the Thematic
Strategies on Sustainable Use
of Natural Resources and
Prevention and Recycling of
Waste, published on 21
December 2005.

In particular EUROPEN
endorses the existing principles
of the hierarchy contained in
the current Waste Framework
Directive and its daughter
Directives such as the Packaging
and Packaging Waste, Waste
Electrical and Electronic
Equipment (WEEE) and End-of-
Life Vehicles (ELV) Directives.
These give first priority to
prevention and make disposal
the least favoured option.
EUROPEN supports the view that the
subject should be treated in the
overall frame of “life cycle
thinking” remembering however
that waste is only one phase of
a life cycle and that life cycle
thinking does not automatically
translate into a need for life
cycle assessments. Mixing waste
management issues with
product-related issues - a
confusion frequently occurring
in the current debate - has to
be avoided.

EUROPEN has expressed its
strong concerns about the
proposals circulating in the
Parliament and Council and
urges MEPs and Member
States to provide for the
necessary flexibility when
deciding on changes to the
Commission’s text.