FEAD cautions against additional changes to the Waste Framework Directive

The European Parliament Committee on Environment published its draft report on the proposal for a directive amending Directive 2008/98/EC on waste, commonly known as the Waste Framework Directive (WFD), in September. This follows the European Commission’s publishing of a targeted proposal to revise the WFD to ensure environmental sustainability in the textiles and food sectors last July.

FEAD, the European Waste Management Association, which is based in Brussels, says these two sectors are the first and the fourth most resource-intensive sectors, respectively, and have not yet fully adhered to the EU waste management hierarchy, which requires prioritizing waste prevention followed by re-use and recycling. Therefore, FEAD welcomed the EU Strategy for Sustainable and Circular Textiles in April 2022 as part of a package to make sustainable products the norm in the EU.

The association says it strongly supports mandatory separate collection of textiles beginning in 2025 to stimulate recycling, move up the waste hierarchy for textile waste and reduce cross-contamination by other waste streams. Textiles need special treatment to enable sorting and recycling and that requires huge investments in treatment capacities, FEAD adds. McKinsey estimates that between 6 billion and 7 billion euros of investment will be needed by 2030 to create the scale of textile processing and recycling the EU wants. To this end, FEAD has supported the creation of extended producer responsibility, or EPR, schemes for textiles from households to incentivize the needed investments, which the Commission’s proposal to revise the WFD included. Therefore, FEAD says, completing the WFD revision is essential to ensure EPR is implemented and to stimulate better sorting for reuse and recycling across the EU.

However, the association says the European Parliament has taken the opportunity of this revision to propose amendments to other parts of the WFD not related to textiles or food waste. It says the proposal includes changing the recycling definition to include fuel production not only from waste is problematic, adding that “such proposal is highly unclear and can put in danger all currently ongoing investments in recycling capacities and technologies.” The initiative also comes at the end of the current mandate of Parliament and the Commission, with limited time to reach agreements.

For these reasons, FEAD says it considers that the scope of the revision must adapt to the available time and warns against any changes in the WFD that go beyond the targeted revision proposed by the Commission. “Opening any discussions on the overall WFD provisions will hamper reaching any agreement at all, with which we risk putting the initiative on hold until the new Commission and Parliament are established after the upcoming elections in June 2024,” the association adds.

"If we want to finish the ‘small’ revision of the Waste Framework Directive still in this mandate, we will need to work hard to find compromises," FEAD President Claudia Mensi says. "As FEAD we are fully committed to make the circular economy work for textiles, but if we start looking at other provisions of the Directive, we are diluting the focus that the Commission has put on textiles and food waste. We cannot forget that these waste flows have been chosen because they represent top resource-intensive sectors causing significant negative environmental externalities, where financing and technological gaps have impeded progress towards the transition to a circular economy and decarbonization. Let’s work together to progress in these two sectors and leave the broader revision of the WFD to the new mandate after the European elections in 2024."