A Risk-based Approach for Waste Management in the Modern Circular Economy: Propositions from the EU Recycling Industries

Abstract

EuRIC, the European Recycling Industries’ Confederation, proposes five regulatory actions to enhance material circularity: i) Set stable regulations based on the principle of "one substance - one assessment" along with realistic, evidence-based scientific risk assessments; ii) Prioritise increasing waste collection for a better elimination of substances of concern to reducing the concentration limit in recycled products; iii) Strict enforcement of an Extended Producer Responsibility (EPR) scheme for all restricted or banned substances, where exemptions should be carefully considered by evidence-based science; iv) Align the classification hazard systems used for waste materials with those used for products; v) Grant an end-of-waste status (EoW) at the output of a controlled, certified industrial loop. Those propositions create a level playing field for collection, sorting, and waste preparation within EU and an improved waste shipment. The underlying question is striking the right balance between the precautionary and responsibility principles in the circular economy. Given the presence of hazardous "legacy" substances and the prolonged life of certain products within an evolving regulatory framework, the recycling industry proposes controlled-risk solutions aligned with the intended use or recycled materials for products not yet ecodesigned. The recommendations suggest a shift in the waste definition, considering the fate of matter within the waste hierarchy—emphasizing prevention, management, and policy alignment with the principles of the circular economy. So, materials that can be prepared for reuse or recycling are categorized as pre-materials, while those suitable only for other recovery methods such as energy recovery or landfilling are considered wastes.