End-of-waste is the point at which a discarded waste product or material gets recovered or recycled to become a substitute for raw materials. It is a step that enables waste to be reclassified as a tradeable product or commodity, usually after processing or a quality assessment.
A set of standard regulations to define end-of-waste are being worked on by the EU as part of its circular economy action plan, which is proving controversial in the recycling sector.
Why does end-of-waste matter?
End-of-waste is important to business because products or materials classified as waste are subject to special waste management rules that limit what the materials can be used for. Waste also has special storage and transport requirements which tend to cost more. From a sustainability point of view, end-of-waste is important because it determines the environmental standards of many products and materials that are bought, sold and shipped around the world.
The regulatory burden associated with end-of-waste standards has an impact on the growth of the circular economy and the extent to which recovered or recycled materials get used in new products instead of virgin materials. Setting a high bar for end-of-waste often makes recycled materials more expensive, deterring their use, which can see more waste ending up in landfill. On the other hand, lower end-of-waste standards can undermine customer confidence in the sustainability of the products they are buying, which can lower demand for recycled materials.
Who decides end-of-waste?
Regulations governing end-of-waste differ widely, both within the EU and further afield. In some EU countries end-of-waste is decided by a governmental authority. In others, the same category of waste can be reclassified as a non-waste product or raw material by the actual waste holder. So the EU intends to harmonise these rules in the hope of eliminating trade distortions and encouraging growth in the circular economy.
Is all waste regulated equally?
No. Some groups of waste are more heavily regulated than others, although this can vary between jurisdictions. Waste paper, for example, is classified as hazardous waste by India, whereas Italy doesn’t classify it as waste at all. Acceptable levels of contamination differ between countries too. An exporter therefore needs to take care that the secondary raw materials they are shipping, along with the accompanying documentation, comply with the regulations of every country involved. Mistakes can lead to penalties or the shipment being rejected by customs authorities, so exporters often hire agents and consultants to avoid this, adding to their costs.
Why are end-of-waste rules controversial in the paper industry?
Setting a new standard for end-of-waste is more than just an environmental issue. In the UK, the Confederation of Paper Industries (CPI) has resisted lobbying to shift end-of-waste for waste paper to before the pulping stage. While advocates suggest that the proposal will promote the export of scrap paper as a usable commodity, benefiting the circular economy, the CPI argues that it would lower standards and leave UK mills with inferior quality material. EU reforms to end-of-waste – if and when they pass into law – are sure to influence the debate.
