A joint letter has been sent by six major UK trade bodies urging the European Commission to implement effective 'pull' or demand-side mechanisms in the forthcoming EU Circular Economy package.

The organisations highlighted recent leaks, which were said to indicated that the package is already likely to contain stronger drivers to 'push' waste out of landfill and up the Waste Hierarchy, including higher recycling and landfill diversion targets.

The six bodies that make up the Trade Association Group (TAG), and have regular informal meetings are: the Anaerobic Digestion and Bioresources Association (ADBA), the Chartered Institution of Wastes Management (CIWM), the Environmental Services Association (ESA), the Institution of Civil Engineers (ICE), the Renewable Energy Association (REA) and the Resource Association (RA).

The Letter in Full

Frans Timmermans
First Vice-President of the European Commission

Circular Economy Package needs to include strong pull measures to sustain recycling markets

Dear Mr. Timmermans

We are writing to you collectively on behalf of the significant majority of the recycling, resource recovery, reprocessing and waste management industries in the United Kingdom. Together, our organisations represent the entire waste and resource supply chain in the UK, from local authorities and private sector collection and treatment companies through to major material reprocessors and the renewable energy sector. Many of our major members are companies with pan-European interests and are well known established European businesses operating across the EU and beyond.

We have all contributed to the recent consultations on the Commission’s revised Circular Economy package and are looking forward to the outcome of your deliberations. Recent reports, however, concerning the prospect of what many would see as weakening ambition from the Commission and ambivalence about the role of pull measures have prompted us to write to you with some urgency.

We wish to associate ourselves with the sentiments expressed to you in an open letter from FEAD addressed to you on 21 October 2015.

In particular, we wish to emphasise to you the importance of the role of pull measures as a central plank of the revised Package. Supply side actions have served us well in many respects to date, but they will be insufficient for the challenges ahead. We all share the ambition for a more circular economy, but we do not see the delivery of a circular economy coming purely from the operation of the market. The Commission is urged to appreciate that in this important area of public policy on the environment and economy, the application of intelligent and proportionate regulation to boost demand for recycled materials should not be seen as contrary to the Commission’s clear strategy to deregulate and operate a ‘lighter touch’ approach to European legislation. It should be seen as a noble exception to the Commission’s general rule, because to deliver the strong environmental and economic benefits of a circular economy requires a long term regulatory framework and market interventions that will stabilise and enhance the viability of increasing recycling.

The history of the growth of our industries in the last thirty years is inextricably interlinked with the value and impact of European legislation on waste, most notably the Landfill Directive and Waste Framework Directive. Our industries have invested and grown along with the clear market signals sent by this legislation. In our judgement, this has worked well and would continue to work well in the next generation and would lead to long term clarity and investment strategies that would drive the European circular economy as well as reduce carbon emissions and create sustainable employment in Europe.

In urging you to look again at the potential for pull measures to advance the circular economy we thank you in advance for your consideration and we remain at your disposal should you wish to examine this in more detail with us.

Yours sincerely

Charlotte Morton, Chief Executive - Anaerobic Digestion & Bioresources Association

Steve Lee, Chief Executive - Chartered Institution of Wastes Management

Jacob Hayler, Executive Director - Environmental Services Association

David Greenfield, Chair of ICE Resource Management Expert Panel - Institution of Civil Engineers

Jeremy Jacobs, Technical Director - Renewable Energy Association

Ray Georgeson, Chief Executive - Resource Association