The European Recycling Industries’ Confederation (EuRIC) welcomes the initiative on the simplification of administrative burden in environmental legislation and underlines the need for making EU legislation more efficient and effective while safeguarding ambitious environmental objectives.

To foster a circular and competitive EU industry, EuRIC highlights that:

• Although we fully support its initial purpose, we believe that the SCIP database can be phased out in its current form. However, the Commission must ensure that future data management tools, such as the Digital Product Passport, improve transparency and traceability of substances of concerns, taking into account their practicability for the recycling and manufacturing industry.
• Simplified and accelerated permitting procedures, less bureaucracy and digitalised and functional processes are crucial to scale up recycling in the EU. EuRIC believes that permitting procedures and subsequent legal actions should be bound at EU level by a specific timeframe.
• Heterogeneous interpretations and implementation of EU rules by Member States create a fragmentation of the single market. EuRIC calls for simplification of definitions under the Waste Framework Directive, harmonized implementation of EU rules, as well as speeding up the development of EU wide end-of-waste criteria.
• When it comes to waste shipments between Member States, EuRIC calls for a simplification of the administrative declaration required for exportation between Member States, mutual recognition of transportation certificates and harmonized rules for the weight of cross-border waste transport.
• EuRIC calls for streamlining reporting frequences and processes (generalisation of the “only once principle”), effective and efficient digitalisation (databases, digital labels related to the Digital Product Passport) with agile digital processes, and simplified reporting criteria for the taxonomy.
• For effective Extended Producer Responsibility (EPR) implementation, EuRIC calls for the simplification of the reporting (i.e. through a single platform) as well as reducing, pooling and simplifying the audits and inspections carried out by EPR schemes. EuRIC believes that the national authorized representative requirement from EPR schemes should be maintained. Moreover, EuRIC calls for a level playing field and equal treatment between social economy entities (SEEs) and commercial operators regarding reporting obligations.
• EuRIC calls for the simplification of the implementation of the regulation for the use of recycled plastic in food contact applications to foster development and increase capacity in the EU.