Feedback from:
Bioenergy Association of Finland
Feedback reference
F502999
Submitted on
20 January 2020
Submitted by
The Bioenergy Association of Finland
User type
Business association
Organisation
Bioenergy Association of Finland
Organisation size
Micro (1 to 9 employees)
Transparency register number
174042620514-51
Country of origin
Finland
Initiative
Circular economy – new action plan to increase recycling and reuse of products in the EU
We hope the New Circular Economy Action Plan will get a significant role in the Green Plan. We see Circular Economy as an important part of the discussions on energy transition & climate change mitigation.
The most effective policy to advance circular economy is to prevent new waste from being generated. We encourage considering further actions that focus on upstream activities of the product chain. Today, renewable materials can increasingly replace materials based on non-renewable resources, and it is important to identify and utilise these opportunities. Customer information on products and rules for marketing of products specially made of non-renewable raw materials is highly supported.
Regarding energetic use of waste, we hope the emphasis will be on improving efficiency of Waste-to-Energy plants and refining of feedstocks into more valuable energy products. It is even possible to achieve negative greenhouse gas emissions in Waste-to-Energy plants using bio-based waste through capture and storage of CO2 from flue gases.
‘Externalising’ materials to non-EU countries in absence of EU facilities that could utilise those material in re-use is a valid concern. It should also be noted that a high end-use cost for recycling of renewable materials may be an incentive to use nonrenewable materials instead. This may often be a counterproductive signal towards the aims of a circular economy