Levelling up on waste prevention and social impact: RREUSE reacts on planned revision of Waste Framework Directive

by | Feb 25, 2022 | Publications






Even though updated not so long ago, the revision of the Waste Framework Directive is highly welcome as the strategy devised in the new Circular Economy Action Plan requires a shift to a better implementation of the waste hierarchy. Indeed, the current waste prevention and preparing for re-use provisions are not concrete enough to lead Member States towards an absolute decrease in waste generation.

With the recent publication of a Social Economy Action Plan and a clear reference to the link between a social and a circular economy, reopening the revision of the WFD is also a great opportunity to reinforce the role that social economy enterprises have in the collection and treatment of waste.

To improve the management of waste in the EU, both socially and environmentally speaking, RREUSE advises the Commission to make the following amendments to the WFD:


  • Targets on waste prevention must be devised in absolute terms, not in relative percentages. Therefore, RREUSE supports Zero Waste Europe’s call for replacing the WFD 10% landfill target with 120 kilograms of residual waste per year per capita by 2030. On top of that, the Commission must accelerate the development of re-use and/or preparing for re-use targets at EU level. At the moment, the WFD only contains promises from the Commission to look into the feasibility of setting such targets by 2025. There is no doubt now that these targets are feasible as many examples (in Flanders, Spain and soon in France and Wallonia) already exist and have positive impacts.


  • Every waste collection model (e.g. door-to-door collection, civic amenity sites, deposit-refund schemes, etc.) must be designed to collect re-usable waste separately. Therefore, article 11.1§1 WFD on facilitating access to the waste stream for preparing for re-use and repair networks shall be expanded. It should include concrete minimum requirements on how waste collection models must be set up to make the separate collection of re-useable items happen at the earliest stage possible, hence safeguarding their re-usability.


  • Support for re-use and preparing for re-use networks to set up alternative collection models for re-usable products. Partnerships between local authorities/producer responsibility organisations and social economy enterprises for the collection of re-usable products are essential to achieve that objective. Re-use operators, especially if they are social economy enterprises and participating in the inclusion of disadvantaged groups on the job market, should not have to pay to deposit donation containers. They should actually be remunerated for participating in the achievement of EU’s waste prevention targets and allowed to install containers in diverse public spaces (city halls, supermarkets, administration offices, private offices, etc.).


  • Reinforce minimum requirements for Extended Producer Responsibility. Producer Responsibility Organisations must also reach concrete waste prevention and re-use targets. For more information on this topic, please refer to the following position paper.


  • Support EU citizens to help them find out where and how to discard their unwanted yet re-usable items appropriately. Financing the development of mapping applications can be helpful in that regard.


  • Prevent the use of counter-productive collection models. The rewarding schemes developed by certain operators (mainly retailers) to collect waste items must be supervised to ensure they do not encourage the consumption of new items (Ex: Textiles retailers giving €5 vouchers for new clothes to clients bringing back waste textiles). If discarders are rewarded, they should be paid cash, not with vouchers. It must also be clear that retailers participating in the collection of waste also have to respect re-use targets and implement the waste hierarchy.