Regler for beregning og verifisering av gjennomsnittlig tapsprosent for kildesortert avfall

We would like to emphasize that the derogation set out in Article 11a(3) and the subsequent rules for calculating average loss rates (ALR) are not relevant for Norway. This is due to the fact that Norway already has detailed requirements for this type of documentation embedded in our national legislation. Norwegian legislation ensures that operators document data and make it available to the authorities. Furthermore, Norway utilizes a well-established Extended Producer Responsibility (EPR) system with comprehensive reporting requirements, which provides data and eliminates the need to rely on calculations using ALRs.

Additionally, Sirk Norge is concerned that the proposed derogation rule, which allows for the calculation of recycling targets based on ALR rather than actual data obtained from the input to the recycling operation, could at worst lead to a decrease in overall reporting accuracy across the European Union.

Finally, we would like to comment on the proposed sampling requirements. The draft stipulates that the sample of sorting activities must be large enough to ensure a statistical error not higher than 5%. We consider a 5% statistical error margin to be highly unlikely and practically unattainable, particularly when dealing with the highly heterogeneous composition of sorted waste due to diversity in sorting behaviour, geography, and seasonal variations.