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GEIR Update

12/12/2018

As part of the implementation of the European Commission’s strategy to drive the EU towards a Circular Economy, stakeholders were invited during autumn 2018 to provide their input on a particular matter: the options to address the interface between chemical, product and waste legislation. The online consultation therefore addressed the four obstacles impeding the uptake of secondary materials:

• Insufficient information about substances of concern in products and waste;
• Substances of concern in recycled materials;
• Uncertainties about how materials can cease to be waste;
• Difficulties in the application of EU waste classification methodologies and impacts on the recyclability of materials (secondary raw materials).

For each of the above, the Commission had identified challenges and proposed policy options to remedy them. Being an active stakeholder, the Waste Oils Regeneration European Industry Association (GEIR) participated in the consultation. GEIR focused on the two challenges which are highly relevant to its activities: improving the certainty of the implementation of end-of-waste provisions, and the level playing field between secondary and primary material.

More precisely, in relation to EU measures to bring about more harmonisation in the interpretation and implementation of end-of-waste provisions, the association made a point of expressing its disagreement with removing the registration exemption for recovered substances provided in REACH. Indeed, GEIR considers that if this option was to be applied, companies which have not registered their substance under REACH should be given a reasonable grace period or an equivalent facilitation system to register. Moreover, access to relevant data should be guaranteed by the respective SIEFs and the bodies managing the SIEFs.

GEIR remains committed to continue its work related to the adoption of the new Waste Framework Directive by providing its support to the Commission in the development of a new reporting template detailing waste oils collection and use.