EU-strategi for en sirkulær, regenerativ og konkurransedyktig bioøkonomi

Sirk Norge strongly supports the main aim of "increasing resource-efficient and circular use of biological resources". Our industry represents the recovery and disposal part of the bioeconomy.

Even though the strategy is a non-legislative initiative, we would like to point out the need for specific policy and regulation measures directed towards the bioeconomy. Such measures should focus on mitigating the circularity and resource efficiency for value chains most hindered by current market failure and low competitiveness. This includes, but is not restricted to instruments such as:

- Member State bioeconomy targets in the Waste Framework Directive, Article 10 and 11.

- National action plans for said targets, in line with the principles of self-sufficiency and proximity laid out in the Waste Framework Directive Article 16.

- Extended producer responsibility schemes where deemed most effective.

- BAT / BREF documents for selected R and D codes involving circular biomass recovery and disposal operations.

- EU wide End-of-Waste (EoW) criteria for selected biomass materials. EoW documents should clearly explain how biomass recovery operations fits in with the waste shipment regulation.

- Best practice guidance on biomass recovery operations, combining terminology from the Waste Framework Directive (R and D operations), the ISO 59004 and the R10 strategy frameworks. Guidance and methodology is also needed for resource use efficiency monitoring indicators for the beforementioned operations. Guidance material should also be required to be integrated into Member State procurement strategies, R&D and innovation strategies, and finance strategies.

- Market mechanisms or criteria that establish an "opt-out", not an "opt-in" responsibility to procure available circular products within a certain geographical radius or value chain availability - whenever available. This would ensure the demand side for emerging and scaling solutions, for SMBs currently struggling to reach profitability and critical mass for scaled up circular solutions.