IN THE NEWS Q1 2022:

Dear Reader,

At the end of 2021, the EU Commission adopted a long-awaited proposal for the new Waste Shipment Regulation. According to the EU, this regulation supports a clean and circular economy. It also tackles the export of illegal waste. Waste exports to non-OECD countries will be restricted and only allowed if third countries are willing to receive particular waste and manage it sustainably.

Breakthroughs proposed by industry, such as the Fast Track procedure for pre-consented facilities, a digital platform for notifications and a system to solve the discussions about classification, are all in the regulation. However, it remains to be seen whether these are real breakthroughs and whether the national and regional authorities of the Member States will implement them. All hopes are pinned on the performance of the digital platform.

We encourage you to study the proposal carefully and forward all questions, suggestions and comments to your contacts at EPMF.

Happy reading!

Jan Robbroeckx, Manager Trade Compliance at Umicore

Revision of the Waste Shipment Regulation


The new Circular Economy Action Plan (CEAP) was adopted in March 2020. It is one of the main building blocks of the European Green Deal, focusing on EU businesses and consumers to transition to a stronger and more circular economy where resources are used more sustainably. CEAP targets how products are designed promotes circular economy processes, encourages sustainable consumption, and ensures that waste is prevented and used resources are kept in the EU economy for as long as possible. The EU plans to assess and revise rules applicable to waste management within this framework.
CEAP is highly relevant to the precious metals sector. The revision of the rules on waste shipments will enhance chemicals and products to enable recycling and improve the uptake of secondary raw materials. It will also substitute substances of concern, or where not possible, reduce their presence and improve their tracking. The main challenges for the precious metals industry are insufficient information about substances of concern in products and waste, their presence in recycled products and difficulties in applying EU waste classification methodologies. To move towards a more circular economy, and in the scope of the revision of the Waste Shipment Regulation, the EPMF recommends the following:
-    Reduce the administrative burden by switching to a harmonised electronic system.
-    Fast track procedures for pre-consented facilities of waste shipments.
-    A harmonised EU approach dealing with waste classification, procedures and enforcement.
-    A general tacit consent by all EU Member States to transit waste for recycling via EU ports without any discharge.
-    Any upcoming regulation should secure a level playing field to avoid low-quality waste stream imports of precious metals, increasing the burden on EU recyclers and refineries.
For more detailed information, please consult the comments from the Eurometaux supported by the EPMF on revising the Waste Shipment Regulation.  

Guest corner: Circular economy through trade  

By Pernille Weiss, Member of European Parliament

The acceleration of Europe’s circular economy is more important than ever. Here precious metals constitute an essential lesson and example; we have to finally acknowledge that waste is a resource rather than a problem. This principle also goes for our regulatory framework, which is currently hampering the full potential of secondary raw materials. In this regard, the revision of the Waste Shipment Regulation plays an important role. Notably, I believe that it holds the potential to facilitate efficient markets for secondary raw materials, in the same way as we see it already for virgin materials. Therefore, the revision should create a truly common EU market for waste by creating a reliable digital infrastructure and minimising the many administrative barriers which hinder trade across Member States today. However, the significance of global supply chains for secondary materials should also not be overlooked. In this regard, the revision can help incentivise environmentally sound recycling practices in third countries and thereby have a positive impact beyond Europe. For open and efficient markets to support the green and digital transition of Europe, we must, however, also ensure that waste crime is combatted. This is why I am also approaching the revision intending to end illegal waste shipments. A lawful actor should never be disadvantaged because others are cutting corners on our environmental standards. Europe’s circular economy must be built on a specific, sound and efficient legislative framework.

Good practice: Revision of the Waste Shipment Regulation

By Lubor Kalafus, Manager Circular Economy at Eurofer

The steel industry welcomes the release of the Waste Shipment Regulation revision by the European Commission. However, significant improvements are necessary to ensure the effectiveness of the revised rules in contributing to the objectives of the EU Circular Economy Action Plan and the EU Green Deal.
Facilitating shipments of waste for reuse and recycling in the EU, not exporting waste challenges outside the EU and addressing illegal shipments of waste are crucial for the European Union to adequately manage waste shipments in a clean and more circular economy and to avoid losses of valuable resources that can be recycled in the EU.
It is essential that the export of waste occurs only when comparable environmental, health and social conditions exist between the EU and third countries, and only when those conditions are verified with certainty.
Significant improvements are necessary to ensure that the proposed measures are effective and that no risks of fraud or circumvention arise. The different treatment between OECD and non-OECD countries, and the subsequent fact that certain destination countries may be exempted from demonstrating the extent to which they meet these essential conditions, is contrary to the spirit of the reform and could undermine the whole system.
The legal presumption applied to OECD countries is not justified because of the Commission impact assessment. At the same time, this approach creates a risk of discrimination among facilities of third countries. Moreover, the legal presumption applied to OECD countries breaches the coherence and effectiveness principles under Better Regulation. Lastly, the safeguard procedure for OECD countries merely addresses potential issues due to the sudden increase of waste flows. Therefore, it constitutes a breach of the proportionality and subsidiarity principle.
The proposed requirement that exporters carry out audits of the facilities where exported waste will be processed is welcome; however, the scope of those audits must be defined with more clarity.
In particular, auditing standards should be defined in the legislative text, while the audit should be performed by an EU-based independent and accredited third party. Regular reporting and transparency requirements should apply, and an effective system of complaints should also be included.
Moreover, a careful evaluation ensures that additional administrative burden will not hinder intra-EU shipment. At the same time, a three-year transition period before the entry into force of the new requirements is excessively long as far as ferrous scrap is concerned.

#PMFacts: how well do you know iridium?

Let’s talk about the lesser-known precious metal – iridium. It was first discovered in 1803 by English chemist Smithson Tennant. The name iridium comes from the Latin word ‘iris’, which means rainbow. It is so named because the many salts formed within iridium are iridescent. Iridium is classified as a transition metal. It is also part of the platinum group family within the transition metals, and they are known for being highly tarnish resistant. How is iridium used in everyday life? The iridium element occurs as a natural alloy of platinum and osmium. Iridium is the most corrosion-resistant metal used in special alloys and forms an alloy with osmium, which is used for pen tips and compass bearings. Currently, iridium demand comes primarily from the electronics, automotive, and chemical industries, as catalysts electrodes coated in a chlor-alkali processes.
Did you know that the international prototype kilogram, which defines a kilogram, is also made of a platinum and platinum/iridium alloy and still in use worldwide?

European Precious Metals Federation a.i.s.b.l.
Avenue de Tervueren 168/6,
B-1150 Brussels

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