The Recycling Forum was launched last January by the European Commission's environment and enterprise directorates (ENDS Daily 27 January 1999). It is due to adopt its report later this month, a draft of which has been seen by ENDS Daily.
The report calls for greater application of "environmental/social cost-benefit analysis" when the Commission prepares waste management measures. Industry is likely to welcome the proposal, having strenuously argued in the context of the 1994 EU packaging directive, for example, that the EU had not demonstrated benefits of packaging waste recycling targets.
The forum has developed a tool which the report says could be used to assess legal targets for packaging, end-of-life vehicles and waste electrical/electronic equipment. EU directives in all these areas are under preparation or are currently being revised.
Focusing on plastics, the draft report concludes that there is a "sensible maximum level" for waste recycling. "Legislation has been beneficial, but a mandated increase in recycling targets will dramatically increase the costs of recycling," it says.
Another pressing issue, the draft says, is the definition of arisings as "waste" or "secondary raw materials" because of the differing regulations applied to the two groups. There is a need for "pragmatic criteria" to draw up guidelines to decide when waste ceases to be waste in the recycling chain," it says.
On possible regulatory measures to increase recycling, the forum says that government-industry voluntary agreements should be considered at national rather than EU level. It suggests the use of economic instruments such as a lower levels of landfill tax for residues from recycling processes, or lower sales taxes (VAT) for products containing recycled material. Attempts to force manufacturers to use minimum levels of recycled materials in their products "could be... against the principle of the free market and competition," it says.
The draft report largely ignores the issue of imposing financial responsibility on manufacturers for the disposal of end-of-life products. "There was no consensus...on whether producer responsibility or shared responsibility was the best approach for improving recycling, or on whether [the former] should mean entire financial responsibility," it says.
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