Review of the Waste Shipment Regulation

Briefing 11-04-2022

The IA convincingly illustrates the identified problems, although their scale is not always supported by estimates, or the source of some of the estimates is not provided. When discussing how the situation would evolve without further action, the IA neither discusses the evolution of each problem identified nor any other existing or upcoming EU initiatives that could lead to improvements. The general objectives appear to be consistent with the problems identified, and the specific objectives comply broadly with the SMART criteria. The retained options tackle the problems' drivers identified progressively, although it is unclear why some of the policy measures identified under Options 2 or 3 were not taken up under the preferred Option 4. The IA appears to assess the main economic, social, and environmental impacts for each policy measure comprehensively, quantifying them whenever possible, and otherwise providing a qualitative assessment. However, the analysis on SMEs is quite limited, and the IA does not provide any explanation as to why competitiveness was not considered. Moreover, despite it likely being relevant, the IA does not appear to have dealt with the impact on third/developing countries sufficiently and systematically. Overall, the monitoring framework envisaged appears to be adequate, although more clarity as to the choice of identifying indicators for only two specific objectives would have been beneficial. Stakeholders were consulted extensively and their opinions systematically reported. The efforts undertaken to provide quantitative support for the analysis performed appear to be convincing, and the IA appears to have addressed the RSB's comments satisfactorily. Finally, the proposal appears to be consistent with the analysis carried out in the IA.