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Waste

Extended Impact Assessment on the Thematic Strategy on the Prevention and recycling of waste

Instructions for responding to the questionnaire:

·        Your comments should be sent to the Commission latest 24 September 2004

·        By responding to the questionnaire form, you automatically give permission to the Commission to publish your comments on this site unless you specify otherwise in your email, fax or mail. The European Union is committed to user privacy, and details of the personal data protection policy can be found at http://europa.eu.int/geninfo/legal_notices_en.htm#personaldata 

·        Your replies should cover economic, environmental and social impacts of the considered options. If you only have information on one or some of these aspects only one or some of the questions, this is of course better than no response at all

·        Your comments should include information on the main stakeholders affected and how they will be affected, benefits and costs (financial/economic, social, environmental, other), and explanation of underlying assumptions and degree of uncertainty

·        The current legal and policy framework should be the benchmark

·        Please provide as much as possible quantitative data on a European scale. However, if you only have qualitative information and/or relating to one or a few Member States only, this can still be useful to us

·        If you are considering specific local conditions, please specify what these conditions are and to which geographical area they correspond

·        It might be useful to illustrate the impacts you describe with concrete examples

·        Please include supporting data and information, and indicate sources and data collection method, including an internet link when available

·        If some of the supporting data/information is not available in a format that can be included in this questionnaire (e.g. paper copy of a report), please send this separately by normal mail accompanied with a copy your filled questionnaire to the following address, mentioning Extended Impact Assessment on the envelope:

            Marianne Klingbeil
            Head of Unit
            European Commission
            DG Environment

 

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  (If you do not belong to an organisation please write "Individual")

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Options Subject to Consultation

 

Strategic Approaches

 

1. Please provide data and/or information on the economic, environmental and social impacts of conducting future waste prevention and recycling policy on the following strategic approach.

a. Waste amounts (weight) are considered as an appropriate approximation for environmental impacts of waste generation and management. Policy is developed to reduce the quantities of waste generated, landfilled or incinerated.

b. Waste amounts (weight) are not considered as an appropriate approximation for the environmental impacts of waste generation and management. Policy is developed to reduce environmental impacts that are important in the life cycle of resources and of products, taking an eco-efficiency approach. A knowledge base is developed on the environmental impacts of waste generation and management taking into account the whole life cycle of resources and products.

 

Optimising the Benefits from Recycling of Waste

 

2. Please provide data and/or information on the economic, environmental and social impacts of setting recycling targets in the  following ways.

a. No further recycling targets - relying on existing legislation and the market to encourage recycling.

b.  Setting material based binding targets that are equally ambitious for Member States and are additional to targets contained in existing end-of-life products directives. This would concern for example inert materials, plastics, rubber, PVC and paper.

c. Setting material based binding targets that are equally ambitious for Member States whilst repealing existing end-of-life products based recycling targets (other provisions relating to collection, dismantling, etc. remaining unchanged). This would concern for example inert materials, plastics, rubber, PVC and paper.

d. Setting additional recycling binding targets that are equally ambitious for Member States for priority end of life products. This could include, for example, furniture, buildings, tyres, toys, newspapers and magazines.

e. Setting targets differentiated by Member State.

f. Basing targets on collection of waste destined to recycling.

 

 

3. Please provide data and/or information on the economic, environmental and social impacts of taking the following measures to achieve waste recycling target.

a. Introducing an obligation for Member States to set waste disposal charges in such a way that the total costs of these operations reach minimum levels, at around 70-90 € per tonne, i.e. broadly equivalent to the cost of incineration.

b. Introducing further producer responsibility obligations bearing on the manufacturers of products, assuming that recycling targets would be fixed at levels so that across the EU the economic costs would not exceed the environmental benefits.

c. Introducing producer responsibility obligations bearing on the producers of materials, assuming that recycling targets would be fixed at levels so that across the EU the economic costs would not exceed the environmental benefits.

d. Negotiating voluntary agreements at EU and/or national level including a mix of measures.

e. Recommending to Member States to systematically implement “pay-as-you-throw” schemes.

 

4. Please provide data and/or information on the economic, environmental and social impacts of taking the following measures to ensure common waste treatment standards for waste treatment facilities throughout the EU, thus achieving a level playing field for recycling activities and for recycled material. Please include data and information on how these options could contribute to reaching recycling targets.

a. Extending the IPPC Directive to all waste treatment operations. Stakeholders should assume that installations below a certain threshold would not be covered.

b.  Defining EU-wide criteria for recycled materials.

c.   Reinforcing the powers of Member States to object to shipments of waste destined to facilities that have lower environmental standards than national facilities.

d.  Reinforcing EU requirements that waste management facilities be subject to regular inspection and reporting obligations such as informing on the flows of waste entering and exiting the individual facilities.

 

 

Waste Prevention

Important note: We are aware that responding to questions 5, 6 and 7 of this section of the questionnaire is difficult. It may be possible for you only to provide qualitative information. You might also want to express your opinion on the issues raised in the questions. We would then ask you to give the evidence on which your opinion is based and to clearly separate opinion from evidence in your answer.

 

5. Please provide data and/or information on the economic, environmental and social impacts of setting the following type of waste prevention targets and would these impacts vary for different categories of waste flows, for example municipal waste, industrial waste or hazardous waste? For options b, c and d, the same level of ambition should be presumed – the question seeks to ascertain the difference in impact of the different methods of calculation of targets not to discuss particular waste flows.

a. No setting of waste prevention targets.

b. Setting weight based waste prevention targets.

c.  Setting substance content based (e.g. heavy metals) targets for qualitative prevention.

d. Setting environmental pressure based prevention targets. This would target pressures that the generation of the waste exerts on the environment, for example emissions of greenhouse gases.

 

 

    

6. Please provide data and/or information on the economic, environmental and social impacts of setting a European weight based target at  the following levels (assuming European annual GDP growth of 3%)? Would these impacts vary for different categories of waste flows,   for example total waste, municipal waste, industrial waste or hazardous waste?

a. Decoupling of waste generation from GDP growth and stabilising waste generation by 2012 to the level of 2002.

b. A reduction of 5% in waste growth by 2012 compared to 2002 levels.

c. A reduction of 10% in waste growth by 2012 compared to 2002 levels.

 

       

7. Please provide data and/or information on the economic, environmental and social impacts of setting waste   prevention targets
in the following way?

a. Setting EU wide indicative prevention targets (All Member States have to reach X %).

b. Setting binding targets at European level that are differentiated by Member States (Member State N1 has to reach X %, Member State N2 has to reach Y %, depending on their individual situation.).

c.  An obligation for Member States to set prevention targets at national level.

 

 

8. Please provide data and/or information on the economic, environmental and social impacts of meeting waste prevention targets through the following categories of waste prevention measures?

  a.  Putting in place producer based measures, such as for example eco-design obligations in the general line of the EuP Proposal.

b.  Production process based measures (e.g. while reviewing IPPC BREFs increase their focus on waste prevention, promote the systematic targeting of waste prevention in environmental management systems).

c.   The promotion of consumer based measures (information campaigns, eco-labelling, PAYT).

d. An obligation for Member States to draw-up waste prevention programmes.

e.  Negotiation of sectoral agreements at EU and/or national level containing prevention targets and a mix of measures.
 
 
 
 

 

Accompanying Measures

 

9. Please provide data and/or information on the economic, environmental and social impacts of taking the following actions relating to the definitions of recovery and disposal?

 a. Adapting definitions of recovery and disposal operation to technical progress within the limits of comitology – this would mean that the essential objective to substitute natural resources would remain central, i.e. as interpreted in current jurisprudence of the European Court of Justice.

b. Reviewing in depth the definitions of recovery and disposal with a legislative act. This would allow the objective of recovery to be refined and the use of criteria to distinguish between recovery and disposal.

c.  Re-organizing the legal framework to move to a waste shipment control system based on the control of waste flows rather than the use of the definitions of recovery and disposal.

 

 

 

10. Please provide data and/or information on the economic, environmental and social impacts of taking the following actions on the definition of waste?

a. No action on the definition of waste.

b. Developing informal guidelines for the case by case application of the definition of waste – dealing with, for example, when a by-product is or is not a waste.

c. Introducing in the waste framework Directive a provision allowing the exclusion from the definition of waste of materials complying with technical criteria – these could include aggregates and bio-diesel amongst others.

 

 

     

11. Please provide data and/or information on the economic, environmental and social impacts of combining certain options, where you consider the impact of a given combination to be important.

 

 

Does your submission include confidential information that should not be published on the Commission's website?

No

Yes  

Please specify in the following field which part of your submission is confidential (if you selected "No" please indicate "None"):