7 January 2016

Commissioner Timmermans' circular economy package lacks detail

European Commission launches Circular Economy Package

Commissioner Timmerman's long-awaited plan for the circular economy has finally arrived. The Dutch Waste Management Association endorses the package's ambition, but misses a sense of urgency. Its success will depend on a credible and concrete implementation programme.

The EU Circular Economy Package (CEP), published at the beginning of December, has been eagerly awaited by the waste sector. European Commissioner Frans Timmermans promised that the package would be ambitious, or at least more ambitious than its predecessor, presented a year earlier. He scrapped that version soon after his appointment, saying the package had to be better and more circular. The latter seems to have been achieved. 'The new package is certainly more circular,' says Dick Hoogendoorn, director of the Dutch Waste Management Association. 'Unlike its predecessor, which focused mainly on waste processing, the CEP addresses the whole value chain and pays more attention to the beginning of the product cycle.'

Two parts

The package consists of two main parts: a revision of four waste directives and an action plan for the circular economy called 'Closing the loop'. 'The action plan is new,' explains Hoogendoorn. The plan sketches a goal horizon and is full of good intentions. For example, the Commission aims to ease the transition to the circular economy, resource use must be reduced to the minimum, and the circular economy will stimulate sustainable growth and create jobs. Hoogendoorn is of course in full agreement with all of this. Who would not be?

Dick Hoogendoorn (DWMA):

"Governments must lead by example through green public procurement."

Too non-committal

The key question, though, is how to get down to the nuts and bolts of the transition. The action plan does not provide much in the way of answers. It is too non-committal, believes Hoogendoorn. 'The action plan lacks urgency. Good intentions alone are not enough. They should be taken up and vigorously acted upon.' The plan's success will depend on how it is implemented. Hoogendoorn argues for a concrete implementation programme in which the transition is spelled out in more detail. He sees it as a second chance. 'The CEP is a first step. The EU must soon come up with concrete actions for making the transition happen. Europe has to make some real choices. By this I mean taking concrete measures, checking that the member states really do carry these out, and imposing sanctions if they do not.' 

The European Commission published its Circular Economy Package at the beginning of December 2015

Pull measures missing

What are missing from the package are the pull measures, actions to stimulate the market for secondary raw materials. 'In this respect the plan fails to live up to expectations,' says Hoogendoorn. He believes positive market incentives are often more effective than dissuasive push measures. As a launching customer the government itself is a crucial driving force behind the transition. 'If we want Europe to make real progress, public authorities must choose circular options in their procurement policies and lead by example. The waste sector must be able to market the materials we recover and produce. We are in the middle of a raw materials crisis, with rock bottom prices for primary raw materials, so governments have to accept that secondary raw materials are going to be a bit more expensive.' Opportunities abound. In the Netherlands alone public authorities procure products and services to the value of 60 billion euros. They can use this purchasing power to make a stand for the circular economy, but in fact this hardly happens at all. A missed opportunity, according to Hoogendoorn.

Other pull measures could also help to kick start the circular economy. For one thing, the waste sector proposes taxing primary raw materials and where possible introducing compulsory percentages of secondary materials in new products. Hoogendoorn finds no mention of such options in the CEP. 'We have to realise, though, that taxes on primary raw materials must be European in scale at the very least, because otherwise the competitiveness of businesses will be damaged.'

Revision of waste directives

Hoogendoorn is more positive about the other part of the CEP, the new waste legislation. 'That we can support,' he says. This part of the CEP contains the proposals for revising the waste directives, such as the Waste Framework Directive, the Landfill Directive and the Packaging and Packaging Waste Directive. At first sight Timmermans appears to have taken a step backwards. Whereas the 2014 proposal contains a target of 70% recycling of municipal waste in 2030, the target in the new package is 65%. Other targets have also been relaxed or scrapped. In one case, seven member states have been given a five year extension on the deadline for limiting landfilling to 10% of the total amount of municipal waste. Their deadline is now 2035. Hoogendoorn sees this as a sign of realism. 'If countries such as Romania, Croatia and Slovakia, which now landfill virtually all their waste, can achieve this goal within 20 years they will have done very well indeed. Don't forget that in 1990, a quarter of a century ago, the Netherlands started to reduce the amount of waste going to landfill and we needed time to do this as well.'

"Invest structural fund money primarily in recycling."

Less ambitious?

Hoogendoorn highlights a key improvement: a clear definition of recycling. 'A new uniform method for measuring recycling percentages will be introduced. Separate collection is now often counted as full recycling, but this is not correct because not all the collected material is actually recycled. Residual streams always remain after sorting and recycling and these have to be incinerated or landfilled. The CEP requires that the recycling percentages should be measured at the end of the recycling process, not the beginning. Hopefully this will finally put paid to the confusion about recycling percentages.' Hoogendoorn thinks that under this measurement method Timmermans' lower target of 65% could well turn out in practice to be higher than the 'more ambitious' target of 70%.

Clean bottom ash

Hoogendoorn would like the method in future to include clean bottom ash as recycling. This is now not the case, which is logical, says Hoogendoorn, because using bottom ash is subject to special protection measures. At least, it is for the time being. 'The sector is currently working hard to make bottom ash so clean that it can be used as a clean building material without restriction. To this end we have signed a Green Deal with the government. If we succeed, I think that bottom ash should definitely be included in the recycling figures.' He stresses, though, that this is certainly not intended as a licence or incentive to incinerate more waste. 'To be absolutely clear on this, incineration with energy recovery should be reserved solely for residual waste that cannot be recycled.'

Spend money efficiently

The transition to a circular European economy requires considerable investments to be made. The CEP acknowledges this, and backs words with action. The Commission has earmarked no less than 5.5 million euros of structural fund money for waste management. Hoogendoorn argues the case for spending this money efficiently: 'Invest public money primarily in recycling. Investment in incineration with energy recovery is also necessary in a circular model, but structural fund money should only be used to build waste-to-energy plants in a member state after first looking to use available capacity in other member states, such as the Netherlands.'

"The action plan is too non-committal and lacks urgency."

Definitions of waste

Hoogendoorn is wary of declassifying residual streams as waste. 'Of course we all want a circular economy in which waste no longer exists, just materials, but the way to do this is not to relax the definitions of waste - or to simply label certain waste streams as by-products. The rules on waste streams are there for a reason. Waste has to be subject to regulation in order to maintain control over it. The government can steer the waste management process, but it cannot control what happens to raw materials.'

Dutch EU presidency

The Netherlands chairs the Council of the EU during the first six months of 2016 and this is an excellent opportunity to take the package forward. 'The Dutch government should seize the opportunity presented by the presidency to come up with a set of detailed proposals for implementation. At the end of June 2016, when the Dutch presidency ends, seems to me a good time to evaluate progress. Then we will see whether the CEP has really got the process going and put a set of measures for the transition to the circular economy onto the agenda. Momentum is building.'