EU Commission study shows end-of-waste is a force for good

The introduction of end-of-waste (EoW) for scrap from iron and steel, aluminium and aluminium alloys has had only positive effects on the market and the environment, according to a major new study from the European Commission’s Joint Research Centre (JRC). Researchers found that it has not caused the disruption to markets and the dramatic increase in EU scrap exports that some had feared.

Three years ago, Council Regulation 333/2011 established criteria by which this scrap could cease to be regulated as waste in the EU. The JRC study examined the impacts of the regulation on scrap availability, trade flows, prices and administrative requirements, as well as on the environment and human health. Approximately 250 companies provided responses to the industry survey, with a further 15 submissions from industry associations and 25 from competent authorities.

The study found “almost no evidence that end-of-waste has caused any negative impacts”, adding: “On the contrary, quite a number of the survey participants, both from industry and competent authorities, highlighted the perceived benefits of the introduction of end-of-waste for metal scrap.” These benefits included “creating a simplified regulatory framework” and “offering companies greater flexibility and legal certainty”. More than 40% of respondents felt that quality on the market had improved for EoW-compliant scrap in particular, notably because of the strict rules on maximum contamination and the wider introduction of quality management systems (QMS).

The study reveals that more than 1100 scrap companies are already using the EoW criteria across Europe, with uptake most pronounced in Italy due partly to the country’s specific legal framework on secondary raw materials that was already in place prior to the introduction of the criteria. The study also estimates that at least 15% of EU scrap steel and 10% of EU scrap aluminium is EoW-compliant.

According to survey responses, the main factors motivating scrap companies to pursue compliance have included: gaining a competitive edge; image improvement; reducing paperwork/costs; and increasing sales values. Indeed, some companies believed market prices had generally risen, with the perceived price premium for EoW-compliant scrap over non-compliant scrap put at an average of 1.1%.

The over-arching purpose of EoW criteria is to: promote high-quality recycling of secondary raw materials; ensure a high level of protection to the environment and human health; provide legal certainty for investment decisions and the treatment of waste; reduce administrative burdens associated with complying with waste regulations; and help the functioning of the internal market by harmonising procedures at a European level. The JRC report is therefore “very important”, says BIR’s Environmental & Technical Director Ross Bartley, because it underlines how end-of-waste has helped towards achieving these goals without disrupting the market and material flows. “Crucially,” he says, “the report shows through government statistics that, contrary to the fears of some, end-of-waste has not increased EU exports of scrap. This has been proved to be an unfounded concern.”

Although some respondents to the JRC study suggested the cost of achieving the necessary QMS certification had outweighed the anticipated benefits, Mr Bartley points out that QMS implementation should also bring wider company benefits on top of the end-of-waste advantages.

And he concludes: “With end-of-waste bringing a quality improvement, among other benefits, the regulation has been shown to be for the general good of the Circular Economy. Everyone should support it.”