Consultation on the Review of the European Waste Management Targets - Response from the Resource Association

Monday, September 9, 2013

Resource Association response to the EU Targets Review consultation:

Overview of our position

The Resource Association appreciates the opportunity to be consulted on EU discussions about Targets.  We consider this Targets Review as an excellent opportunity to further cement the desire of the Commission for a resource efficient Europe that manages resources more wisely and encourages the utilisation of resources within the EU economy for the building of an eco-resilient economy less dependent on factors outside our control. In saying this, we support the maintenance of healthy and legal exports of material resources as part of the global economy but recognise the longer term imperative for Europe in building resilience from global insecurity and rebuilding our manufacturing base able to utilise secondary raw materials within the EU economy. 

We support a broadly more ambitious approach to the setting of targets in the EU, but importantly this must be set alongside an urgent need to standardise the use of data and definitions across the EU so that there is consistency and a level playing field in interpretation. In addition, while we support ambition for the whole of the EU, it must be realistic to develop a more sophisticated approach that recognises the starting point of many (especially newer) EU Member States who are presently very dependent on landfill and have very limited recycling infrastructure. 

A multi-layered approach to target setting and improvement from baseline would surely be more realistic and give all Member States a full and fair stake in our overall resource efficiency objectives. This approach should run alongside a fresh impetus across the EU to develop an eco-industrial strategy that encourages and incentivises greater use of recyclate by manufacturers in an EU-wide approach to market development.  Without this, higher targets will be very difficult to achieve and not based on any sensible future reality - the two approaches must go hand in hand - higher targets and eco-industrial strategy.  This will set us firmly on the path to the resource efficient Europe that the Commission set out so clearly in its Roadmap and which we continue to support.

Read the full response from the Resource Association.