Humana Position Paper on the amendment of the Waste Framework Directive

22-07-2024

As the European Members and Associates of Humana People to People, we look forward to the upcoming Waste Framework Directive trialogue negotiations and wish to share our analysis of the new provisions and offer recommendations on the final wording.

The body of this document briefly presents our main standpoints and associated rationale. The annex proposes alternative wording of the actual provisions, wherever relevant.

Calendar, targets and measuring methodology  

  1. EPR schemes should be implemented as soon as possible.
  2. EPR schemes’ performance should be measured against collection, reuse and recycling targets.
  3. No operator should be exempt from reporting obligations.

Scope of EPR fees

  1. Reuse operators should not pay EPR fees.
  2. Micro enterprises should not be exempted from EPR fees.

Role of Social Economy Entities and other actors

  1. Governance of EPR schemes should involve all stakeholders.

Collection and handling operations

  1. Mandatory collection of used textiles by January 1st 2025 should be kept.
  2. Local sorting should not be mandatory.
  3. Ownership of materials should stay with the collector.

Position Paper on the amendment of the Waste Framework Directive

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