Lifting the waste status must be subject to strict conditions

The revised Waste Framework Directive (WFD) has opened the possibility to lift, through comitology, the waste status in respect of certain waste streams. This proposition is attractive to Member States as it will reduce the total volume of waste and facilitate progress towards national waste reduction targets. It may also stimulate resource efficiency by creating a market for new ex-waste products.

CEMBUREAU recognises that lifting the waste status will be inevitable and may be justified for a limited selection of waste streams but insists that this is to be achieved only under strict conditions:

• Only non-hazardous, specifically defined waste streams destined for material recycling should be considered for lifting of the waste status;
• The waste status must not be lifted for mixed waste;
• After sorting, the product must be free of contaminants, with a maximum of 1% of impurities left; and
• The lifting of the waste status must only be considered once all recovery operations have been completed.

Lifting the waste status should not become an easy way to by-pass waste legislation and should not lead to a leakage of valuable ex-waste materials, circulating freely as products, out of the EU.

Co-processing of waste in the cement industry is recognised as a “best practice” when it comes to resource efficiency. Lifting the waste status in the EU must not deprive the cement industry of an essential energy source and of access to valuable raw materials. Co-processing in the EU should be encouraged, not relocated outside of the EU where, at the very end of the product life, the strict environmental conditions imposed in the EU are not necessarily guaranteed.

Co-processing of waste in the cement industry is an advanced and innovative recovery process whereby not only energy is recovered but also the non-combustible part of the waste, which is reused as raw materials. This resource efficient process should gain full recognition in the waste hierarchy.

The ongoing developments on End-of-waste criteria at European level are of major importance for cement producers. Last year, CEMBUREAU had

already issued a paper proposing end-of-waste criteria for used tyres. CEMBUREAU continues to follow-up the process but is also pro-actively preparing contributions to these discussions. Two new documents were recently issued:

• Scope of Solid recovered fuels – waste streams used in the cement industry
• CEMBUREAU proposal for End-of-waste criteria for specific waste streams – recyclable fractions

CEMBUREAU is currently preparing its input into the study on the suitability of waste derived fuels for end-of-waste status which has been commissioned by the European Commission.