In July 2023, the European Commission proposed a targeted amendment to the Waste Framework Directive, introducing specific rules on textile and food waste. ACR+  welcomes the proposal, as it is a stepping stone towards the advancement of circularity of resource intensive products, and towards the reduction of environmental and climate impacts linked to their production and disposal. One year and a half later, with both Parliament and Council still to vote on the proposal, ACR+ reflects upon the missed opportunities of the revision, as well as complementary actions needed to strengthen and enforce the provisions once adopted. 

Addressing the waste problem at its roots: further focus on prevention  

According to the European Commission, an average European produces 5 tonnes of waste every year, and only 38% of the total waste in the EU is recycled. Despite efforts to decrease waste production, the quantity of waste has increased: between 2010 and 2018, the total amount of generated waste increased by 5% in Europe (EEA, 2023).   

At this pace, it seems unlikely that the EU targets of significantly decreasing the material footprint and the total amount of generated waste will be met by 2030 (EEA, 2023). The role of legislation is key in reducing consumption where necessary. In this context, waste prevention has an important role to play as it can reduce resource use, maximize the useful life of products and materials, and promote demand for more sustainable waste-free products.  

Within the current revision of the Waste Framework Directive, a prevention target for both sectors tackled in the legislative proposal should have thus been proposed.  

While measures to prevent food waste generation are referred to in Article 22c of the revision, no targets on textile waste management have been introduced, although this type of waste has been identified as the EU's fourth largest cause of negative environmental impacts after food, housing and transport (EEA, 2022). The production of textiles generates significantly higher climate change impact than their retail, use and end of life management (EEA, 2022). Legislation should thus cast focus on prevention. Extending the life of clothing items is important, but the roots of the textile waste issue lie in the overproduction of items driven by fast fashion, which the EU Strategy for Sustainable and Circular Textiles also identifies as a major problem to be addressed. Currently, almost all EU Member States have some quantitative targets on waste prevention, but the sectors to which they apply and the objectives vary widely (EEA report, 2023). Only by introducing EU-level waste prevention targets for textiles will the legislative revision be able to effectively tackle the actual problem, setting the direction and an objective for measurement and to strengthen obligations on waste prevention. The targets set for waste  electrical and electronic equipment, including for recovery and recycling or preparation for reuse, are a good example which should be replicated for textiles.  

Legislators should thus further focus on reuse, which can both deliver environmental benefits and social benefits. Some of these include fighting against poverty by providing affordable products to low-income households, fostering social inclusion by bringing disadvantaged people back into the labour market and society, thanks to the creation of jobs in collection, sorting, testing, refurbishment and reselling of items reused.

Along with prevention, reduction of textile consumption is also to be achieved by regulating the amount of new garments that suppliers can place on the European market.   

Harmonization of EPR Systems across Europe 

Article 22a of the proposal establishes a mandatory and harmonized Extended Producer Responsibility for textiles across all Member States with eco-modulation of fees. 

The introduction of several articles in the Directive laying down requirements for Member States to introduce EPR schemes for textiles allows to place greater responsibility for waste management onto producers. While the proposed addition is to be praised, ACR+ regrets that the proposal lacks harmonization and standardization provisions, thus opening the door for fragmented implementation and fulfillment of the requirements  across Member States. While the WFD foresees implementing acts to ensure harmonization if desired or required, the extent and implementation of existing EPR schemes in different Member States is inconsistent, as they diverge in terms of product scope, cost coverage, fee structure (categories and granularity), fee modulation criteria, and reporting requirements. The fragmented approach of this instrument significantly limits its impact while increasing the administrative burden on legislators and on retailers, especially those placing products on the market in multiple EU countries (ref).  This reality starkly contrasts with the EU common market approach fostering continuity rather than fragmentation. The Waste Framework Directive is to this date the most binding instrument able to promote harmonization of EPR across the EU, and ACR+ deems that the latest revision has not placed enough focus on this very important issue. 

Futhermore, while the addition of provisions for an EPR scheme for textile is a promising start, ACR+ deems that a full and separate piece of legislation is needed to properly address definitions, sorting and recycling requirements, waste and non-waste status, roles and responsibilities of the various actors, status of social enterprises active in the collection and treatment of textiles without creating loopholes. This is because textile and textile waste are a vast and complex sector, as much as batteries and waste from Electrical and Electronic Equipment, fractions for which EPR is already in place. In this sense, the ongoing assessment of the WEEE Directive carried out by the European Commission can also help to understand the gaps and opportunities of the EPR scheme, and learnings can be useful for the application of similar systems to other sectors. 

Raising the ambition and extending the scope of food reduction targets  

The newly inserted Article 9a prescribes that Member States shall take the necessary and appropriate measures to achieve, by 31 December 2030, a reduction in the generation of food waste in processing and manufacturing, by 10% in comparison to the amount generated in 2020. The article also sets the goal of reduction in the generation of food waste per capita,  by 30 % in comparison to the amount generated in 2020 for the retail, distribution, HORECA sector and households as a whole.  

While supporting the introduction of food waste reduction targets at food value chain level, ACR+ regrets the low ambition shown by the Commission in tackling the food waste challenge. The above-mentioned targets are well below the 50% per capita reduction targets set in the Sustainable Development Goals (SDG) 12.3 target set for 2030, which were originally endorsed by the European Commission. Moreover, a 30% overall reduction across retail, distribution, HORECA and households leaves room for avaraging effects, foregoing the opportunity to design specific food waste reduction strategies that are responding to the flaws of specific market segments and actors.   

Still, to set in place an efficient and target-oriented food waste reduction and prevention system, these provisions ought to go hand in hand with the establishment of effective monitoring and control schemes. That would allow to keep track of the progress towards the set reduction targets in each Member State. When it comes to integrated municipal waste, such monitoring systems would need to be able to analyze the sorted volumes of organic versus residual waste, and to compare these data throughout time to quantify potential reductions.   

Moreover, ACR+’s opinion is that it is paramount for the European Commission to set up a more granular, timely and effective sanctioning system to be enforced upon Member States falling short on the targets. The extension of the Early Warning report to food waste will be useful in anticipating implementation weaknesses. However, the EWR and connected recommendations to MS alone are not binding instruments.  A concrete sanctioning system is thus needed to enforce the attainment of targets ahead of the established deadline. 

Another aspect to be accounted for is that while in its incipit the article 9a mentions that Member States shall take appropriate measures to prevent generation of food waste in all steps of the chain, from primary production to distribution of food, the proposal does not set reduction targets for the primary production. Yet, it is estimated that approximately 90 million tonnes of food losses occur at this stage, three times as much as EU households food waste (31 Mtons) (EEB, 2022). The food loss prevention challenge faced in primary production represents a considerable waste of natural resources like soils’ nutrient, water and energy at source, while food can remain unharvested for lack of market or labour, or for not meeting retailers’ specifications due to aesthetics or size criteria. As in the case of textiles sector, the food sector is overproducing, which in turn causes waste. 

To conclude, when it comes to food, ACR+ regrets the low level of ambition of the waste reduction target proposed in the Revision, and the exclusion of the primary production stage from the target scope. As for textile waste, ACR+ regrets the lack of prevention targets in the Revision, which would have contributed to mitigating the overproduction of garments and current fast use and dispose trends creating excessive amounts of waste. Moreover, ACR+ calls for a separate piece of legislation to ensure homogenous and standardized implementation of the EPR scheme for textiles across Member States. 
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