AfvalOnline: 'Malta is undermining the circular economy'

Storm clouds are gathering over the waste and recycling companies. The Maltese EU presidency is sending the circular economy in entirely the wrong direction.

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Malta is undermining the circular economy

Storm clouds are gathering over the waste and recycling companies. The Maltese EU presidency is sending the circular economy in entirely the wrong direction.

©copyright Uitgeverij Noordhoek (Translation: Derek Middleton)

The European Commission (EC) is rolling out its Circular Economy Action Plan and the European Parliament voted in March to raise the bar just that little bit higher, but the European environment ministers seem to be going in exactly the opposite direction. Waste industry representatives in Brussels are viewing the trickle of ideas and proposals from the Maltese presidency with growing alarm – although some interest representatives are perfectly happy with the way things are going. We analyse the differences of opinion. 

Respite for the stragglers

The biggest concern for CEWEP (the Confederation of European Waste-to-Energy Plants) is pushing back the landfill targets. ‘Member states that rely heavily on landfill should actually view the targets in the Circular Economy Package as an opportunity,’ argues Ella Stengler of CEWEP. ‘If those member states get an extra ten years to reach the targets instead of the five years proposed by the EC, it will be 2040 before the landfilling of municipal waste is reduced to 10% of total arisings. This would be a lose-lose situation for the environment, the economy and jobs.’ Piotr Barczak of the European Environmental Bureau (EEB) thinks it is simply too bizarre for words. ‘The biggest change is extending the deadline for the countries at the back of the pack by ten years! The ministers are in effect rewarding the worst performing countries with a further postponement.’

The cement industry sees it differently. Although the industry’s representative body Cembureau (European Cement Association) agrees that phasing out landfill provides the main impetus for recycling, it also believes that member states failing to keep pace with the recycling targets should be given more time to set up an efficient national waste management system. Vagner Maringolo, Cembureau’s environment and resources manager, points to the announcement made at the start of this year by the EC that member states should take a long-term view when building up their waste management structure and planning incineration capacity. This includes taking account of the situation in neighbouring countries and the availability of co-combustion capacity, for example in cement kilns.

Recycling targets

Most organisations do not consider the recycling targets to be sacrosanct, with the exception of the EEB. ‘Lower recycling targets go against the interests of society and governments alike. The EC itself has calculated that the higher targets proposed by the European Parliament could deliver an extra 580,000 jobs by 2030 and save 72 billion euros of raw materials,’ says Barczak.

FEAD (the European Federation of Waste Management and Environmental Services) wants ambitious but realistic targets, but thinks that how the targets will be set is ultimately more important. CEWEP argues that the emphasis should be less on the quantity of waste recycled and more on the quality of recycling. ‘Clean and effective recycling is more important than just high volumes. Only high quality recycled products will earn the trust of consumers,’ says Stengler. She thinks that the definition of recycling must require the substitution of primary raw materials. Nadine de Greef of FEAD takes a slightly different view. ‘Measuring recycling at the point where the waste enters the final recycling process may be the best option for some waste streams, such as food waste, which is almost always delivered directly to the composter or anaerobic digester, but this is different for materials like paper and plastic that first have to go through a pre-treatment stage, such as sorting. When they finally arrive at the treatment stage where they are processed into raw materials they are often mixed with similar materials from non-domestic sources or from other countries.’ De Greef therefore wants the recycling percentages to be based on the amounts of waste leaving sorting centres. Guarantees would be needed that those outputs are actually recycled and that any unusable material is subtracted from these amounts. Vanya Veras of MWE (Municipal Waste Europe) takes a more pragmatic approach. ‘The key thing is to harmonise the way recycling rates are measured across the EU, even if this means that initially we have an imperfect system. This can be adjusted at a later date.’ She is also keen to point out that the discussion leans heavily on household waste. ‘The EU waste directives are not transparent regarding information on commercial and industrial wastes, which make up 75% of the total.’

What is municipal waste?

De Greef is pleased that the European Parliament has insisted that the definition of municipal waste should have nothing to do with whether it is treated by a public or a private body, but she is worried that it may be watered down. ‘Municipal waste is waste from households and waste of a similar nature, composition and quantity.’ She wants to stick with that definition. ‘All three conditions should remain, and certainly that of quantity. If you leave that out, the volume of commercial waste treated as municipal waste will increase, which means that taxpayers will be paying for waste produced by businesses.’ Veras thinks the criteria of nature and composition are enough. ‘The Maltese presidency has proposed excluding waste from big companies and industry from the definition, but that has little point if “big” is not clarified and will only lead to litigation.’ 

What is recycling? 

There is widespread unease about the decisions on recycling being made under the Maltese presidency. Stengler is concerned that the Council ‘seems to becoming increasingly generous regarding what counts as recycling’. 'This includes vague formulations such as including, in addition to compost or digestate, other output with similar quantity of recycled content as recycling. What is "other output"? [It is now clear that this includes output from mechanical biological treatment (MBT) – ed.] And why should it be a similar quantity of recycled content? What about the quality?' 

Barczak is opposed to the idea of classifying the output from mechanical biological treatment facilities that meet certain quality criteria as recycling. ‘Some member states already count this as recycling, but it only discourages source-separated collection of organic waste, and that is precisely where we should be heading.’

What surprises Stengler most in the most recent proposal by Malta is that even municipal waste (mineral fraction) going to co-incineration should now count as recycling if it takes place simultaneously with energy recovery. ‘Co-incineration is not recycling. The definition of recycling does not include energy recovery,’ she says. Barczak (EEB) backs her up. ‘Making waste suitable for energy generation does not recover any raw materials; it is a form of energy recovery.’

But Maringolo of Cembureau takes a very different view and looks to the member states who will support the Maltese amendments. ‘Co-firing household waste in a cement kiln produces ash residues that can be used as a raw material in the production process. In Portugal this could increase the recycling percentage for packaging from household waste by 2.6%.’ According to Maringolo these combined recovery operations are recognised in various EU documents, particularly in a guidance document from 2012. ‘The energy is recovered from the waste in an R1 process and the mineral fraction is used in the manufacture of cement pavers, an R4 or R5 process.’

Barczak says that this would bring a long cherished wish of the cement industry within reach. ‘The first problem is that it is almost impossible to determine exactly how much material is recycled compared with the amount that is incinerated. Second, household waste first has to be converted from a refuse derived fuel to a solid recovered fuel, which opens a Pandora’s box for fiddling with the boundaries between energy recovery and recycling.’ Moreover, he thinks that if co-incineration of household waste can count partly as recycling, the same principle should be applied consistently across the board. ‘The bottom ash from WtE plants would then also be residues of household waste. If they are landfilled they would have to be added to the landfill statistics, which would make it a real struggle to keep within the 10% landfill ceiling in 2030.’

The crucial question facing the environment ministers, therefore, appears to be what the member states really want. Do they have the courage to embrace the circular economy by establishing a materials cycle, or will they choose the option of very slowly winding down landfill combined with incineration with energy recovery, and even co-incineration in cement kilns? The incineration option will deliver good statistics, but not a circular economy. Or, to cite Barczak, ‘In the context of the circular economy, incineration is wasteful and brings the materials cycle to a standstill.’ For him, incineration is the option of last resort when recycling and reuse are no longer possible. 

Producer responsibility

Another cause for concern is the extended producer responsibility (EPR). Barczak: ‘The current text for stricter directives is actually quite weak: it just states that the EC has the option of issuing directives. We want eco-design to be a fundamental part of the EPR and the contributions paid by producers to be based on the actual costs of disposal. The proposal before the ministers is to weaken that by only “taking it in consideration”. Also, the criteria should be set at the EU level, because otherwise member states will be too inclined to take their own individual approaches.’

According to Veras, though, that is not the crux of an EPR. ‘Minimum requirements are not introduced primarily for harmonisation, but to provide clarity to local governments and producers. The EPR systems must be transparent regarding the flows of materials and money, and the producers should bear the full costs. In addition, there should be no doubt that governments are responsible for waste management and therefore free to choose who should carry out these services.’ FEAD agrees with the transparency and minimum requirements, but no more than that. ‘An EPR must be driven by the market so that costs can be kept to a minimum and efficiency maximised,’ says De Greef. ‘The EPR systems should also stimulate the use of secondary raw materials and provide long-term contract security so that the parties involved can make the necessary investments.’ De Greef also thinks that member states should ensure that the contributions paid by producers for the EPR system must be sufficient to cover all the costs of the system. ‘It is important that new requirements for EPR systems do not disrupt existing B2B markets for commercial waste or existing EPR programmes that already work well.’

Market for secondary raw materials

Lastly, FEAD wants to emphasise the importance of creating a mature market for secondary raw materials. The Circular Economy Package should contain measures to stimulate demand. However, the extremely low prices of primary raw materials are putting the producers of secondary materials under intense pressure, De Greef points out. ‘Market incentives are needed to enable fair competition with secondary raw materials. Current market prices do not reflect the political weight behind secondary materials. For example, there should be obligations for sustainable procurement and rules on the use of secondary materials in the manufacture of certain products,’

Barczak finishes by calling for waste prevention. ‘What is glaringly absent are binding targets for waste prevention, especially for food and marine litter. This would be in line with the international commitments made in the Sustainable Development Goals.’

Ella Stengler (CEWEP):"Clean and effective recycling is more important than just high volumes. Only high quality recycled products will earn the trust of consumers."
Nadine de Greef (FEAD):"Market incentives are needed to enable fair competition with secondary raw materials."