Conclusions and recommendations
The EESC welcomes the fact that material efficiency has become DG Environment's key priority.
The goal of material efficiency could be served simply by fine-tuning and balancing existing systems and production processes with the help of well-defined incentives. The EESC warns that neither the number nor quality of jobs in the recycling and process industries can be compromised.
Large volumes of collected secondary raw materials are currently being exported although they are badly needed in the European basic and process industries. This trend seriously jeopardises employment in all the process industries.
Unfortunately, illegal trading practices are often used in order to circumvent direct control of important secondary raw material flows.
The conflict between market forces and the existing regulatory framework should be analysed in detail to achieve better balanced results. One possible suggestion could be to apply export duties to protect against the risk of losing valuable materials. Such measures would obviously have to comply with WTO rules.
Another option would be to agree on flexible recycling targets depending on actual market developments, i.e. during market downturns (reduced demand), the recycling targets could be lowered, while during boom phases of high demand, they would go up.
Yet another option would be to make recycling targets/quotas equivalent only to volumes of waste that could be re-used within the EU, not including waste sold abroad that could not be used in EU facilities. However, such a measure should be accompanied by resetting targets/quotas to match actual EU recycling capacities.
The EESC strongly supports the industry's call upon the EU to develop a comprehensive and consistent policy on long-term sustainable access to raw materials and use of resources.
All the individual elements of the EU Climate Change Policy (ECCP) should take into account the environmental benefits of secondary raw materials (SRMs), and inconsistencies should be avoided.