Contribution to the ongoing discussion

VCI Position Paper on the review of the EU waste legislation and and on the EU circular economy

The EU Commission has withdrawn its proposal of July 2014 for amending the EU waste legislation, announcing another proposal for end 2015. This new proposal is planned to go far beyond the purely waste-specific aspects and will also address, for example, the fields of resource efficiency, product policy and recycling materials (so-called secondary raw materials). As these topics impact the chemical industry in many ways both directly and indirectly, the VCI wants to make a constructive contribution to the ongoing discussion with this position paper

Outline of the present situation

Chemical industry wastes in figures (status 2012) – Waste management has an important role in the industry

Waste management costs in the chemical industry are roughly 600 million euros per annum. In total, some 2.7 million tonnes of wastes are generated every year in this industry. This total consists of up to 100,000 different waste streams. The share of hazardous wastes amounts to nearly 50 percent; it is bound to be above average as compared with other industrial sectors. For this reason, the chemical industry depends particularly strongly on adequate waste law framework conditions also in this field. Here, the focus is frequently on the energy recovery of hazardous wastes as the essential disposal route.

Sustainable waste management in the chemical industry – successful in waste avoidance and recovery

The German chemical industry is strongly committed to a sustainable waste manage-ment. This means, first of all, that – by way of waste prevention measures – the waste generation must be kept lower than the economic growth. The German chemical industry has succeeded in this. Furthermore, the disposal routes need to be ecologically sound, economically acceptable and technically feasible.

The chemical industry has successfully and demonstrably fulfilled these requirements, too: by means of a balanced mix of material recovery (preparation for reuse and recycling) and energy recovery. It is worth noting that over two thirds of all wastes from the chemical industry are channelled into recovery.

But irrespective of all efforts, in the production activities of all industries – including chemistry – it is inevitable that wastes are generated which have no longer any use from the ecological and economic perspective. Such wastes go into well-organised and regulated disposal, for the protection of humans and the environment.

The chemical industry has built up its own modern disposal infrastructure for both the recovery and the disposal of wastes. Moreover, the industry closely cooperates with carefully selected external disposal service providers.

Resource efficiency in the chemical industry – a matter of course

From the chemical industry’s viewpoint, resource efficiency is the efficient use of raw materials and other natural resources for the production of products. The companies themselves have the greatest interest in maximum efficiency. Together with fierce competition, the high raw material costs ensure that the largest possible product volumes are obtained from every tonne of raw and input material. Against this backdrop, the chemical industry has consistently expanded its “Verbundproduktion” (integrated production). As a matter of principle, optimising the production processes is a permanent task of the companies. Wastes are avoided wherever this is possible, or they are recovered as materials or energy. This reduces the consumption of primary raw materials and primary fuels. In other words: The chemical industry puts unavoidable wastes to good use by turning them into resources.

Next, chemical industry products enable resource-efficient consumption, because their use helps preserve resources. For example, the use of numerous chemical products saves many times over the amounts of energy that were needed in their production: Solar cells and wind power plants for electricity generation, high performance batteries, fuel cells, lightweight construction materials, fuel-saving car tyres, insulants or heat accumulators for energy-friendly housing – such innovations are possible only with the know-how and the products of the chemical industry.

The research & development efforts of chemical companies are another major contribution to the sustainable use of resources and to further increases in resource efficiency.

Summary of the VCI’s messages and demands

EU waste legislation

  • The existing EU waste legislation sets a high waste law standard.
  • Implementation and correct enforcement of the existing waste legislation in all Member States must have priority over new waste law provisions.
  • Introducing time-limited interim targets might be helpful.
  • The Member States should support each other by delegating officials/civil servants, where necessary.

Resource efficiency

  • The chemical industry has become active early and achieved much in the field of resource efficiency.
  • Resource policy needs the right sense of proportion so that industry remains competitive globally and can thus drive forward resource efficiency with its products.
  • Absolute reduction targets, taxes or levies/charges for the use of resources would impair much needed growth and, consequently, they would also hamper the necessary innovations and developments.

Waste recovery

  • Waste is an important resource for materials and energy.
  • Waste recovery should be seen in a holistic and differentiated approach.
  • Both recycling and energy recovery are perfectly justified options.
  • The best suited recovery option depends individually on the nature of the respective waste stream.
  • Potential levies/charges, taxes or similar on incineration have no ecological steering effect, so that they would constitute unnecessary burdens on industry.
  • Energy recovery of (hazardous) wastes makes an important contribution to resource efficiency and environmental protection (destruction of harmful materials).
  • Recycling must not become a purpose in itself.
  • High-quality recycling and high-quality recycling materials should be in the focus – instead of non-differentiated recycling approaches.
  • A tightening of recycling targets – regarding both the calculation method (changeover from the “input perspective” to the “output perspective”) and the absolute amount, without taking into account ecological and economic impacts – is rejected.
  • Material-specific recycling targets for mass wastes are not suitable to bring the desired results.
  • Recycling of critical raw materials needs to be looked into separately.
  • Recycling must not lead to a carry-over of harmful substances.

Producer responsibility under waste law

  • The producer responsibility under waste law is already highly exacting.
  • First of all, the existing requirements need to be fulfilled in all Member States, observing the principle of subsidiarity.
  • A tightening of producer responsibility – leading to the producer bearing the full end-of-life management costs – would be disproportionate, detrimental to competition, and stand in contradiction to the polluter-pays-principle.
  • Actions for consumer information as well as an effective interplay between the public administration and the disposal industry would be suitable to reach the desired goals.


  • Landfilling remains necessary also in the future for wastes that are no longer recoverable, i.e. wastes that can be no longer used as a resource.
  • Non-differentiated landfilling bans would be counterproductive economically and could not be put into practice.
  • Landfilling bans should be limited essentially to municipal waste suitable for recovery.
  • Potential levies/charges, taxes or similar on landfilling have no ecological steering effect, so that they would constitute unnecessary burdens on industry.

Waste legislation versus chemicals legislation

  • A level playing field is needed for primary and secondary raw materials.
  • There must be no legal grey area for so-called secondary raw materials.

Waste management for industrial and commercial wastes

  • Specific aspects of industrial waste management are regulated in the BREFs. Therefore, no additional requirements are necessary in new legislative proposals in this field.
  • Specific features of packaging wastes from industry and commerce need to be taken into account.


  • Waste legislation already includes numerous bureaucratic obligations.
  • Additional bureaucratic requirements bring no additional ecological value and constitute burdens on industry and the economy.

You will find the full position paper including an assessment in detail (17 pages all in) in the download section at the top of this page.

For your questions and suggestions, please feel free to contact us. Your contact person within VCI:

Prof. Dr. Winfried Golla
Phone: +49 (69) 2556-1418