Waste Shipment Regulation revision: Cerame-Unie’s feedback to the inception impact assessment

Circular economy
8 April 2020


Cerame-Unie, the European Ceramic Industry Association, welcomes the upcoming revision of the Waste Shipment Regulation as announced in the new Circular Economy Action Plan adopted by the European Commission on 11 March 2020.


Cerame-Unie agrees on the obstacles with regard to the implementation of the Waste Shipment Regulation as identified in the evaluation, such as the current paper-based procedures and the lack of harmonised approaches in different Member States. Thus, Cerame-Unie welcomes the objectives of the initiative as underlined in the Inception Impact Assessment:


  • facilitate preparing for re-use and recycling of waste in the EU, thereby adding value to waste in the EU


Facilitating reuse and recycling of waste will add value to waste and better support the transition to circular economy. Cerame-Unie stresses that some of the current procedures do not facilitate transboundary movements of waste for reuse and recycling within the EU.


  • simplify and reduce burdens linked with the WSR’s implementation in general, and in particular to ensure a smooth functioning of the EU internal market for waste destined for recycling or re-use, and support its transition to circular economy models


Cerame-Unie approves the objective to simplify and reduce burdens linked to the Waste Shipment Regulation implementation. Indeed, the ceramic industry highlights that shipment of waste between Member States is a complex process and leads to administrative overburden for manufacturers. Thus, provisions to further harmonise the implementation of certain procedures and to reduce unnecessary regulatory and administrative burdens are welcome. Furthermore, as the material sources and the manufacturers are not always close to each other, transportation costs of end-of-life products and of secondary raw materials limit uptake and competitive advantage of recycling material. Thus, a smoother exchange of waste for reuse or recycling will strengthen the functioning of the EU internal market for secondary raw materials and will result in a level playing field as regards waste management.


As a conclusion, Cerame-Unie underlines that a policy that effectively implements the objectives set out by the new Circular Economy Action Plan should make a decisive choice towards considering waste as a resource. This can be only achieved if waste intended for re-use or recycling is treated as goods. Thus, there is a need for a clear separation between the scheme applicable to waste destined for disposal and waste destined to valorisation that must benefit from the principle of free movement of goods within the EU. The revised and strengthened Waste Shipment Regulation should apply to waste intended to be sent outside the EU, while the internal rules for End of Waste, which must become uniform and mandatory for Member States with a radical simplification of burdens, should be strengthened.