Consultation response to EU proposal on circular economy
IVL Swedish Environmental Research Institute has submitted a response to the European Commission circular economy package. IVL believes the proposal to be both positive and progressive, and applauds the holistic approach taken to drive development towards a circular economy.
To some extent, the package adopts a preponderantly hands-on and concrete approach, for example, revised legislation is proposed for the waste sector, where well-defined targets can be established within the EU to leverage recycling and waste reduction. In its response, among other things, IVL emphasizes that it is vital to find a common statistical ground, i.e., develop methods that can be used to measure waste streams – both to address recovery targets and food wastage. However, the package does not deal with critical issues brought about by industrial waste streams. This is partially addressed when production and industrial symbiosis are ventilated, but IVL believes that it would be appropriate, for example, to place greater demands on manufacturing companies to use recycled material and thereby create a market for these materials. It is also positive that the proposal clearly distances itself from overcapacity in connection with treatment low down in the waste hierarchy (mechanical biological treatment, and incineration), and clearly states that investment funds are to be used to reward solutions that make it possible to treat waste at higher levels in the hierarchy. When it comes to consumption, IVL appreciates that the position the Commission takes in the initial text is proactive; the Commission wishes to ensure that product prices better reflect environmental costs by applying fiscal instruments such as taxes. Instruments to promote innovative forms of consumption and collaborative economy solutions, sales of services and control via public procurement are also discussed. But when it comes to laying down the necessary measures the Commission takes a step backwards. IVL would rather that the Commission dared address challenges in a practical and concrete manner, and not just note their existence. Document Consultation response: European Commission Communication, COM(2015) 614/2: Closing the Loop An EU Action Plan for the Circular Economy (In swedish)