Adam Schlüssler, EPHI's Waste Manager, reports live from Brussels on developments around the EU Waste Framework Directive.
The targeted revision of the Waste Framework Directive aims to strengthen separate collection requirements, extend producer responsibility, improve recycling performance and harmonize monitoring across the EU, with key milestones running from the Commission's proposal on 5 July 2023 until Parliament's planned plenary vote on 9 September 2025. Following informal trilogues, a provisional agreement was reached on 18 February 2025, and the Council's position was published in the Official Journal of the European Union on 10 July 2025. The proposed changes strengthen waste management and producer responsibility, but also risk increasing regulatory burdens and potential market disruption, which requires careful scrutiny.
Tax: Where the review is defensible
Harmonization reduces transaction costs: A common EU framework reduces cross-border regulatory fragmentation for the trade in secondary materials and reduces compliance costs and legal uncertainty for companies operating in several Member States. Uniform rules can increase liquidity in recycling markets and attract investment in recycling infrastructure where scale is crucial.
Creating credible demand for secondary inputs: Clear quality and monitoring rules can increase buyers' confidence in recycled materials, reduce transaction friction and price volatility for industries that can replace primary raw materials with high-quality recycled materials.
Junk: Where the review risks market disruption
Prescriptive process requirements risk technology lock-in: Parliament's committees and plenary have introduced concrete collection and process requirements. Imposing specific collection methods or overly detailed technical requirements favors established technologies and can stifle innovation. A market-oriented policy should focus on outcomes (environmental performance) rather than prescribing specific means.
Unreasonable burden on SMEs: Extended producer responsibility and intensified monitoring/reporting increase administrative costs. Industry stakeholders repeatedly warned in the 2023-2024 consultations that SMEs face relatively higher compliance costs, which may raise barriers to entry and reduce competition.
Rigid quotas can lead to inefficient recycling: Binding quotas and sector-specific targets risk imposing recycling where it is economically or environmentally inappropriate.
Competitive disadvantage and leakage risk: Stricter EU standards without corresponding measures or border adjustments can raise production costs for EU companies compared to non-EU competitors. This risks relocation of production and carbon and resource leakage beyond the EU's borders, unless policies are complemented by trade protection measures.
Conclusion
The revision of the Waste Framework Directive contains elements that should be welcomed by market supporters, such as harmonization, clearer signals to producers and stronger markets for secondary materials. However, the current approach also contains "junk" elements in the form of regulatory mandates and administrative burdens that risk technology lock-in, marginalization of SMEs and reduced competitiveness.
The vote on 9 September in the European Parliament will be a defining moment: policymakers should prioritize market-based flexibility over regulatory requirements to safeguard innovation, competition and cost-effective environmental outcomes.
Primary sources
- European Commission, Proposal for a Directive amending Directive 2008/98/EC on waste, 05/07/2023.
- European Parliament committee on Environment, Public Health and Food Safety report (committee adoption), 14/02/2024.
- European Parliament plenary first-reading position, 13/03/2024.
- Trialogue / provisional agreement notes, 22/10/2024; provisional agreement 18/02/2025.
- Council Official Journal (C), 10/07/2025.
