The EU Environmental Policy agenda for 2012 is focused on Sustainable Consumption and Production. In February 2012, the European Commission launched a public consultation on how to transform Europe into a sustainable economy. The issues the European Commission consults on include: development and role of environmental footprint of products, augmenting competitive rewards for environmentally friendly products, strengthening the requirements concerning resource efficiency, enhancing Green Public Procurement and ecolabels, putting in place incentives for businesses to develop green products, etc. The European Re-refining Industry is contributing to the public consultation emphasizing its support for the transformation of the EU economy to a sustainable one as well highlighting the importance of Green Public Procurement uptake in the EU including some mandatory measures which would play an important role.
Furthermore, the European Re-refining Industry was involved in the development of a Best Practices Guide for Member States on economic instruments to support the Waste Framework Directive implementation. This initiative is a deliverable from the Roadmap for a Resource Efficient Europe and comprises of European Commission collecting useful examples across the different industries which can be included in a Best Practices Guide to be finalized at the end of 2012. The purpose of the Guide is to disseminate efficient examples across the Member States so they can learn from each other. GEIR members provided examples of economic instruments which support the collection and give priority to re-refining of waste oils rather than energy recovery. Some good examples exist in Finland, Italy, Spain, etc.
Moreover, GEIR continues to exercise pressure to the European Commission to respond to the UK Environmental Agency on the problematic of Processed Fuel Oil Protocol (UK PFO). This Protocol is not in compliance with the EU Waste Framework Directive because used oil is not recycled but it’s transformed in a fuel to be burnt without any emissions control, hence not complying with the EU Waste Incineration Directive. The classification and the end-of-waste definition stated by UK Environmental Agency creates a distortion in the European market favouring trans-boundary shipments of a dangerous waste into a country where the European waste hierarchy has not respected giving priority to incineration rather than to recycling. Finally, a precious resource like waste lubricating oil that can be easily recycled several times is lost when is burnt and this creates a negative impact on the entire lube oil life cycle assessment. The European Commission has already replied to the UK Environmental Agency that it has doubts that the Processed Fuel Oil Protocol complies with the Waste Incineration Directive which the UK authorities contested. The European Waste Oils Regeneration Industry is dissatisfied with the fact that European Commission is not defending its position and EU legislation. Fabio Dalla Giovanna, Honorary President of GEIR said: "I expect the European Commission give an answer to UK authorities as soon as possible strengthening the priority order of the WFD hierarchy and confirming its first statement regarding the WID compliance”. GEIR will continue to engage with the relevant actors to influence the UK PFO issue.
Last but not least, the European Waste Oils Regeneration Industry worked on influencing the situation of recyclers under REACH. Currently, waste is excluded from REACH and recovered substances do not have to be registered. However, while legally this is beneficial to recyclers, the lack of registration number presents a commercial problem. Essentially, customers are now used to work with REACH and are aware that all substances manufactured/imported and placed on the market must have a registration number. No registration number equals to no market and gives the perception that these substances are illegal. In addition, e-tenders have predefined parameters and include a REACH registration number box – no registration number excludes recyclers automatically from the tender. In this respect, GEIR is active within an alliance called Recovery and Recycling Industry Chain (RRIC). A RRIC position paper was drafted on the issue of registration numbers for recyclers and presented to the European Chemicals Agency. As a solution, the European Chemicals Agency will develop a leaflet where this issue will be clarified among others as well as Frequently Asked Questions will include a relevant question - both to be finalized in June 2012.
In the coming months, the European Waste Oils Regeneration Industry will continue its advocacy efforts on issues related to UK Processed Fuel Oil Protocol and end of waste, sustainable consumption and production, EU waste hierarchy and its proper implementation, REACH and evaluation of the Guidance on recovered substances, modernization of EU public procurement rules and enhancing the Green Public Procurement aspect in it, etc.