Review of the EU waste management targets - 'Circular Economy Package': Initial Appraisal of a European Commission Impact Assessment

01-02-2016

The additional analysis accompanying the new 'Circular Economy package' goes a considerable way towards addressing some of the concerns previously voiced with regard to waste targets in the context of the original IA and legislative proposal, especially the criticisms regarding the apparent failure to take sufficient account of the different situations of the Member States and their capacity to perform in the future. It provides further evidence of the possible impacts of new waste targets by considering a number of alternatives to one of the original options (option 3), and by presenting the results of an updated application of the model used for the original impact assessment. In particular, costs were updated to 2015 prices, and data on waste was drawn from the latest available Eurostat sources (2012). The use of sensitivity analysis (carried out on the main input parameters used in the model, e.g. efficiency of the collection system, material losses and revenues, etc.) is another welcome indication of the desire to provide a realistic assessment of the likely impacts of the proposed measures. A clearer ranking of the options presented - and of their variants - might nevertheless have allowed for a more thorough appreciation of the potential impact (and benefits) of each of the new alternatives considered, as well as for a better understanding of the coherence between the new proposal and the overall impact assessment analysis. As mentioned, some questions concerning subsidiarity and proportionality - especially as to the issue of landfilling of waste - are left partially unaddressed. Finally, the analysis, though thorough, is clearly intentionally restricted to an exploration of the possible impacts generated by the new sets of waste targets. It does not seek to go further in 'exploring synergies with other policies' - one of the reasons set out in the April 2015 Roadmap, referred to above, for the withdrawal of the original proposal.

The additional analysis accompanying the new 'Circular Economy package' goes a considerable way towards addressing some of the concerns previously voiced with regard to waste targets in the context of the original IA and legislative proposal, especially the criticisms regarding the apparent failure to take sufficient account of the different situations of the Member States and their capacity to perform in the future. It provides further evidence of the possible impacts of new waste targets by considering a number of alternatives to one of the original options (option 3), and by presenting the results of an updated application of the model used for the original impact assessment. In particular, costs were updated to 2015 prices, and data on waste was drawn from the latest available Eurostat sources (2012). The use of sensitivity analysis (carried out on the main input parameters used in the model, e.g. efficiency of the collection system, material losses and revenues, etc.) is another welcome indication of the desire to provide a realistic assessment of the likely impacts of the proposed measures. A clearer ranking of the options presented - and of their variants - might nevertheless have allowed for a more thorough appreciation of the potential impact (and benefits) of each of the new alternatives considered, as well as for a better understanding of the coherence between the new proposal and the overall impact assessment analysis. As mentioned, some questions concerning subsidiarity and proportionality - especially as to the issue of landfilling of waste - are left partially unaddressed. Finally, the analysis, though thorough, is clearly intentionally restricted to an exploration of the possible impacts generated by the new sets of waste targets. It does not seek to go further in 'exploring synergies with other policies' - one of the reasons set out in the April 2015 Roadmap, referred to above, for the withdrawal of the original proposal.