Hazardous Waste Europe (HWE) welcomes the https://ec.europa.eu/environment/publications/proposal-new-regulation-waste-shipments_en
We are very pleased to see that most of the main issues raised by HWE have been addressed with concrete and appropriate proposals:
- adaptation of the amount of waste in case of experimental treatment trials,
- clarification of the timing and deadlines regarding the requests for information,
- clarification about the effective end of a notification period,
- streamlining the conditions under which a facility can be pre-consented,
- implementation with deadlines for the electronic data interchange system,
- new perspectives to solve cases of disagreement on classification issues with a warning point on our strong expectation for the implementation of article 6 point 2 of the Waste Framework Directive.
Nevertheless, HWE urges the European Commission, the European Parliament and the Members States to improve the proposal on the following points:
- Ensure that POP non-hazardous waste are covered by the prior written consent procedure,
- Include in the ESM perimeter the management of residues generated by the waste treatment as they are likely to be mismanaged, specifically in third countries. Not only disposal but also recycling operations should be covered because recycling operations may lead to the generation of hazardous residues when decontamination is properly performed,
- Ease public access to notification,
- Adapt requirements of article 11 to the case of hazardous waste management. Hazardous waste facilities including those providing disposal operations are the ultimate barrier to reach a toxic free environment, to avoid toxic recycling and to get rid of substances of concern. The network of specialised facilities has been built in compliance with the self-sufficiency principle at EU level stated in the Waste Framework Directive (WFD). As a consequence of this principle, the hazardous waste treatment sector acted in a responsible way to avoid export of hazardous waste outside the EU and EFTA countries and to limit at the minimum intra European Union shipments for disposal which represent only between 2% and 3% of the European wide hazardous waste production(*). For hazardous waste management, the proposed article 11 ignores the effort provided by the sector which has proven its efficiency in the past years and disregards the requirements set out in article 16 of the WFD.
(*) excluding WEEE & ELV not managed by hazardous waste operators but mainly by Producer Responsibility Organisms or Traders