Ref. Ares(2023)809321 - 03/02/2023
Mr Frans Timmermans
Executive Vice-President for
the European Green Deal
Mr Virginijus Sinkevicius
Commissioner for
Environment, Oceans and
Fisheries
Brussels, 06.07.2021
Re.: Revision of the Regulation 1013/2006 on Waste Shipments
Dear Executive Vice-President, dear Commissioner,
The ambitions of the
EU Green Deal and the release of the
New Circular Economy Action Plan have
imparted fresh momentum to the transition of the EU towards climate-neutrality and circularity.
Furthermore, the importance of keeping a functioning recycling value chain in the EU, from waste to
new‐end products, has also been stressed. There is a need to ensure the recovery of valuable materials
from waste and their availability to the industry in order for the EU to be less dependent on imports
of virgin materials.
These aspects were emphasised in the recently published communication on the
‘EU Industrial
Strategy’ and in the
‘Critical Raw Materials Resilience: Charting a Path Towards Greater Security and
Sustainability’.
European steel is at the heart of European industry and is responsible for
330,000 direct, and 2.6
million indirect jobs, in the EU. This is
highly skilled, quality employment, and we need to keep these
jobs in Europe especially during the closely linked green and digital transitions. The European Social
Partners, the European Steel Association (EUROFER) and industriAll Europe, fully support their
members in working towards a carbon-lean, environmentally responsible, circular and internationally
competitive European steel sector.
However, although the European steel sector is keen to improve its circularity by increasing its use of
scrap metal, the period between 2015 and 2019 saw a sharp rise in ferrous scrap exports from the EU‐
27, rising from 9 million tonnes to
15 million tonnes in 2019. This fact is highly concerning as ferrous
scrap has a
emissions reduction potential of between 1.4 and 5 tonnes CO2 during the steel making
process.
Access to European scrap ferrous metal is essential for the decarbonisation of the sector, which
includes the journey to becoming fully circular. Unfortunately, the EU remains a massive exporter of
waste (
26 million tonnes in 20191), preventing European industries from becoming more circular.
1 https://ec.europa.eu/eurostat/databrowser/view/cei_srm020/default/table?lang=en; Circular Economy
monitoring framework; indicator ‘Trade in recyclable raw materials EU-27’ based on the waste streams
containing: plastic; paper and cardboard; precious metal; iron and steel; copper, aluminium and nickel.
Moreover, these exports of waste result in much higher greenhouse gases emissions. They could lead
to social and health problems because waste processing in third countries often takes place under
conditions that do not meet the same standards on the environment, labour and safety as those in
Europe
. For the sake of the environment, worker’s rights and public health, this trend of rising waste
exports needs to stop.
The
European Parliament’s Resolution 2020/2077(INI) on the New Circular Economy Action Plan highlights this critical point: It recognises the need to ‘
halt the export of waste to third countries that
cause environmental or human health damage and to tackle the unlawful behaviour more effectively
with the aim of ensuring that all waste is treated in accordance with circular economy principles’.
The European social partners support this demand and insist that
the
exports of secondary raw
materials be better regulated. More specifically, exportation should only be allowed when the country
of destination demonstrates its commitment towards climate, environment, worker rights and ILO
fundamental rights.
In other words, it has to show to have implemented equivalent standards on the environment
(emissions control and waste management), climate (ambitious climate targets and specific
instruments for cutting GHGs) and human health (including workforce rights and safety).
We, the European social partners, have supported the European Commission and the European
Parliament in their work in this area, and we urge EU policy makers to continue their crucial efforts by
ensuring that the revision facilitates the effective transition towards a climate-neutral and truly circular
EU economy.
Therefore, the European steel social partners, EUROFER and industriAll Europe, call on EU policy
makers to use the revision of the Regulation to ensure that it effectively regulates the exportation
of EU ferrous scrap, a precious circular raw material which is essential to increasing the circularity
and the decarbonisation of the European steel sector, and re-establishes a level playing field
between Europe and third countries, both in its environmental and social aspects.
We want to express our appreciation for your consideration of our letter and we remain at your
disposal to discuss the review of the Waste Shipments Regulation (1013/2006) with you at your
convenience.
Yours sincerely,
industriAll European Trade Union
The European Steel Association (EUROFER)