Innspill: EUs utkast til end-of-waste (EoW) kriterier for plast

Sirk Norge strongly supports the intention of establishing harmonized criteria for when plastic waste ceases to be waste (End-of-Waste).

Establishing a functioning market for secondary raw materials is crucial for the circular economy. However, we question whether the proposed technical criteria actually support the goal of a robust market, or if they risk exacerbating the cost disadvantage recycled materials already face compared to primary raw materials.

Our first concern is the exclusion of chemical recycling, which is proposed to be postponed for evaluation until January 1, 2029. Sirk Norge believes this delay hinders the goal of increased use of recycled materials. Chemical recycling is a necessary technology to reach recycling targets for plastic types that are not suitable for mechanical recycling. We urgently request a "fast-track" process for chemical recycling, rather than waiting until 2029, to ensure Europe’s access to secondary materials.

Regarding the technical requirements, the proposed < 1.9% limit for foreign materials presents a significant barrier. While the limit is achievable for high-purity streams, a rigid application risks excluding established recycling streams that are crucial for the circular economy. We specifically point to two problem areas identified by our members where "impurities" do not compromise product integrity:

1. Plastic from metal cable recycling: Fractions derived from cable recycling often contain metal residues exceeding 1.9%. This material is currently successfully used to manufacture die-cast base products (e.g., heavy bases for temporary fencing and signage). In this specific industrial application, the weight provided by the metal residue is a functional quality, not a defect.
2. Residues from household packaging: Recycling of complex household plastics often yields non-melted residues of polyethylene (PE) mixed with other technical plastics (such as PA/nylon from laminates, PC, or PMMA) that are difficult to separate completely. These streams are also used for die-cast base products. The main proportion is PE and laminates of PE/PA, where the presence of these compatible polymers does not pose a risk.

If these functional materials remain classified as "waste" due to strict purity limits, their use is restricted to facilities holding specific waste management permits. By granting End-of-Waste status through targeted derogations, the Commission would enable a wider range of manufacturing actors to utilize these resources, thereby expanding the market.

Sirk Norge therefore recommends that the regulation allows for specific derogations or higher threshold values for defined industrial applications where inert foreign materials (such as metal fragments) or compatible polymer residues pose no environmental risk.

Furthermore, regarding the export restriction to "one thermoplastic polymer", we ask for clarification that ensures legitimate blends (e.g., PE/PA laminates) are not unfairly penalized.

Finally, we are concerned that the proposed administrative requirements, specifically the frequency of third-party certification and sampling (at least every 6 months), are disproportionate. If administrative costs become too high, they will counteract the competitiveness of recycled plastic compared to primary raw plastic. While we support a zero-pollution vision, requirements for sampling and analysis of hazardous substances must be practically feasible for industrial operations without halting legitimate material flows.