Flexibility in the Waste Framework Directive is Essential

Flexibility in the Waste Framework Directive is Essential

FEFCO welcomes the En­vi­ron­ment Council’s decision to allow more flexibility to deviate from the waste hierarchy.
“The deviation clause that was
supported by the European Parliament in its first reading would require companies to un­der­take a life cycle assessment and cost-benefit analysis each time they want to deviate from the hierarchy. This approach would be too costly, time-consuming and bureaucratic. The approach taken by the Council is much more flexible since it is based on life cycle thinking and takes into account technical feasibility, economical viability as well as overall environmental, human health, economic and social impacts”, said Angelika Christ, Secretary General of FEF­CO.
FEFCO is more doubtful when it comes to the steps of the waste hierarchy itself, having repeatedly denounced the five-step hierarchy in favour of a balanced approach between reuse and recycling, and this since the start of the legislative process in December 2005.
Based on sound scientific evidence (such as the study ordered by the Commission on the implementation of the Packa­ging and Packaging Waste Directive, there is no justification to favour reusable packaging systems over one-way recyclable alternatives.
Furthermore, by ranking the reuse of products under prevention, the Council is ignoring the environmental impact caused by reconditioning. If the reuse of products were to be ranked under prevention, Member States would be inclined to promote reuse as a part of prevention. This would have a significant impact on the internal market as non-reusable but recyclable packaging would be discriminated against for unjustifiable reasons, leading to market distortions and, eventually, to more court cases and not to a better environment. Finally, with respect to prevention FEFCO is of the opinion that he EU should avoid developing 27 different programmes but welcomes the proposal to develop guidelines to assist Member States in the preparation of the programmes, guidelines which should be based on the Essential Requirements contained in the Packaging and Packaging Wa­ste Directive (94/62/EC).