The EESC welcomes the Commission's Proposal for a new Regulation, and the accompanying Communication, and considers the protection of human health and the environment to be a top EU priority. When technically possible, waste produced in the Union should be recycled within the Union, in an environmentally, economically and socially sound manner.
The EESC calls on the Member States to adopt the Electronic Data Interchange system (EDI) as soon as possible, agree on adopting harmonised criteria for pre-consent procedures, and empower the Commission to adopt delegating acts for common waste classification. It also calls for the extension of the EDI system to all waste shipments destined for export, import and transit.
A transition towards new business models that give back to the planet more than what they take is urgently needed. Health and safety and working conditions must be well protected and monitored. The EESC calls for investments in training for workers through a specific allocation under the ESF+.
The EESC calls for enhanced funding opportunities for establishing and/or modernising the EU's recycling facilities and discovering innovative technologies for the reuse and recycling of waste. Boosting recycling capacity inside the EU's borders will contribute to reducing carbon and environmental footprints and lead to increased employment in this sector.
The EESC believes that a harmonised financial guarantee calculation should clearly cover all the risks arising from waste shipments, but must not overburden companies, especially SMEs. It also welcomes the Commission proposal for third-party audits on external waste facilities and considers that social partners and relevant NGOs should be part of procedures. National and European strategies that involve social partners, SMEs and NGOs are needed and have to be promoted through collaborative platforms. The European Circular Economy Stakeholder Platform is an excellent example in this regard.
The EESC considers that exports of high-quality recyclable waste, and especially waste exports with a high content of critical raw materials, are detrimental to EU sustainability and undermine its global competitiveness.
OECD member countries should meet the same strict criteria regarding environmental commitments as non-OECD ones, and proof of evidence should be provided that all the receiving countries are already managing their own domestic waste in an environmentally sound manner, and respecting the ILO core conventions and labour standards.
The EESC supports the enforcement of the inspection and investigation procedures and calls for full cooperation between Member States and with the Union. Non-confidential data should be made publicly available to all interested parties, including social partners, NGOs, municipalities and citizens.
The EESC invites the European Commission to assess the possibility of establishing a Market Observatory for secondary raw materials, with a consultative role for the European Commission, that can analyse and recommend sectoral development policies and ways to eliminate the existing bottlenecks, and retain valuable secondary raw materials within the EU.
Finally, the EESC calls for a maximum two-year transition period after the Regulation is adopted and for a thorough impact assessment of the implementation of the Regulation five years after its entry into force.