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- End-of-waste status for Paper for Recycling: Why a reassessment is overdue
End-of-waste status for Paper for Recycling: Why a reassessment is overdue
The starting point is clear:
Paper for recycling has been functioning exceptionally well for decades.
That's particularly true in the commercial and industrial sectors. Recycling rates of close to 85%, and well above 90% in some countries, demonstrate that a high-performing and resilient recycling system has become established in Europe. The European paper industry and the waste management sector have jointly created a market in which supply and demand have long worked hand in hand.
Yet this is precisely where the central conflict lies. Existing waste legislation pursues important objectives: it protects the environment and human health, conserves resources, and provides the legal framework for a functioning circular economy. For many waste streams, this regulation is indispensable.
In the case of paper for recycling, however, it is increasingly argued that these same bureaucratic requirements are having more of a restraining than a protective effect.
A material stream with established quality standards, functioning sales markets and proven industrial recovery pathways should not be subject to the same administrative burdens as waste streams requiring a higher level of supervision.
The fact that the debate is gaining new momentum now is largely linked to the introduction of DIWASS.
Recent months have shown just how much coordination is required for new documentation and monitoring processes.
Specialists from the waste management sector, paper industry, logistics and IT have invested considerable resources in implementation. DIWASS may be appropriate for those waste streams that struggle to meet recycling targets, are problematic in processing, or for which no sustainable markets exist. For paper for recycling, however, the question arises as to whether this effort is substantively justified - or whether an end-of-waste regulation would be the far more consistent and efficient approach.
A prerequisite for such a step would be that paper for recycling meets defined quality requirements and is subject to a transparent, audited quality assurance process. In this context, particular reference is made to the grades in groups 1 to 4 under EN 643, which, subject to appropriate sorting and/or quality assurance, could meet the end-of-waste criterion. The key requirements for this are broadly well known:
The material must be intended for a specific use in the paper industry, there must be a market for it, quality criteria must be in place, and its use must not cause greater environmental impacts than the use of a comparable primary raw material.
The potential advantages of an end-of-waste regulation are obvious.
Supply chains could be aligned more closely with market mechanisms, administrative processes would be significantly reduced, and the organisation of storage and transport could be simplified — naturally while retaining necessary safety requirements, for example in fire protection. Particularly within the European single market, where the free movement of goods is a core principle, such simplification could bring considerable efficiency gains.
That such an approach is practicable is already demonstrated today by existing regulations for other material streams. At European level, end-of-waste regulations exist, among other things, for steel scrap, copper and glass.
As regards paper for recycling, Italy is frequently cited as a national example.
A regulation has been established there that is regarded in the sector as a robust reference framework. According to information from the market environment, no negative effects have been observed since its introduction; at the same time, the high recycling rates are taken as an indication that regulatory clarity and practical efficiency are not mutually exclusive.
The discussion about end-of-waste status for paper for recycling is therefore more than a technical regulatory issue.
It touches on the very core of the European circular economy: how can environmental standards, resource efficiency and economic practicality be meaningfully reconciled? In the view of many actors in the sector, the answer is clear. Where markets function, quality standards are established and ecological risks remain manageable, regulation should enable rather than hinder. For paper for recycling, now may be precisely the right time to draw that conclusion in legal terms as well.
