International recycling trade organisations are reacting with concern to the European Commission's proposals for revising the EU Waste Shipment Regulation (WSR). While embracing the underlying objectives of protecting human health and the environment and ensuring the environmentally sound treatment of waste, industry organisations such as the European Recycling Industries’ Confederation (Euric) and the Bureau of International Recycling (BIR) warn that in its current form, the revised text would be counterproductive and ultimately hinder the transition to a circular economy.
In its response to the newly published legislative proposal Euric criticises what it sees as a "one-size-fits-all" approach which fails to make any distinction between untreated problematic waste streams and "raw materials from recycling" which can be used directly. Instead of restrictions on exports, Euric advocates for increased use of binding recycled content requirements, that had so far "proved to be the most efficient yet least utilised instrument" in the EU Commission's toolbox.
Both BIR and Euric warn that the measures proposed by the Commission would cut excess secondary raw materials off from international markets, making them "captive in Europe". BIR went a step further, saying that it saw in the proposal an "open intention to reduce the cost of materials within the EU". The artificially lowered prices of the materials would "affect the capacity of the European recycling industry to invest in efficient and innovative recycling capacities and processes", the international federation cautioned.