Analysing the Dutch end-of-waste system

To effectively move towards a circular economy, it is essential to have both regulatory-driven incentives and robust safeguards in place that address any potential health and safety concerns. This is particularly important when these concerns arise from the use of recycled materials or substances derived from waste. The end-of-waste status intends to assist in addressing exactly these aspects.

The responsibility of providing evidence to support the self-declared end-of-waste status lies with the recycler. However, there are substantial uncertainties surrounding how to determine the level of safety required, and what legal certainty it offers recyclers and users of recycled materials.

The European Commission and the Dutch government have set policy goals to increase recycling rates. This emphasises the recycler’s ability to distinguish between waste inputs and product outputs. To enable recycled materials to no longer be labelled waste and simultaneously prevent unintended safety risks for humans and the environment, the European Commission has drafted end-of-waste criteria. The criteria are included in the Waste Framework Directive (WFD) and are designed to establish when waste becomes a product during recycling, and therefore obtains its so-called end-of-waste status (i.e. Einde Afvalstatus). However, when exactly can compliance with the end-of-waste criteria be claimed, and who decides if the end-of-waste status is achieved for a recycled substance?

Invest-NL and Groene Chemie Nieuwe Economie (GCNE) are actively engaging with, and investing in, new start-ups and scale-ups with novel recycling solutions. Their efforts are focused on initiatives to recycle plastic or biobased waste streams. Recyclers from their network are in need of easily accessible information on the end-of-waste system. They lack legal certainty on the end-of-waste status and find that it is unclear what type of (analytical) information and analytical test result need to be available. Ecomatters was asked to complete an in-depth study of the end-of-waste system. We identified practical issues and highlighted suggestions for improvement.

Relevant regulation was reviewed and interviews and surveys were completed by recyclers. The main outcomes of the report are divided into two parts:

1.  actionable advice to recyclers on how to navigate the current system;
2.  specific suggestions for policymakers to improve the system.

The report enables Invest-NL and GCNE to design the next steps to improve the end-of-waste system. In addition, it helps recyclers to better understand and navigate the Dutch end-of-waste landscape. In turn, this enables more recycled substances to reach the market and new recycling initiatives to get investment.

Download the report here if you want to know more

On April 17th, 2023 GCNE organised the “No Time to Waste” event in The Hague. During this event, Ecomatters presented the outcomes of the report. Additionally, the event facilitated constructive discussions between business representatives and policymakers around the identified barriers and suggestions for improvement. A detailed account of the event can be found here.