Paul Sanderson’s report


Last week, the Council of The Recycling Association agreed to use a small portion of our reserve funds towards working with the Environment Agency to develop end-of-waste criteria for paper and cardboard.

In a process started by my predecessor Simon, we are putting together a joint application with the Environmental Services Association to try and achieve end-of-waste criteria for paper and cardboard. 


Both organisations are sharing the costs equally, which involves funding the time of Environment Agency officials in going through the detail of our application and joining meetings. It also potentially requires us to fund research, technical studies and possibly other actions that will require a financial commitment.

Why are we doing this?

As we move towards a circular economy, we need circular product standards so that recycled materials can be traded as a product rather than a waste. As a product, it would not fall under the same regulation and legislation as a waste. This could mean not requiring filling in Annex VII forms and meeting the inspection criteria of some export destinations. Domestic mills have the opportunity to specify and buy this high-quality commodity too. 

It seems to me that the European Union is moving towards a system where they will ban some exports such as plastics, or add tougher rules on audits for paper and cardboard, while encouraging end-of-waste for the export of higher quality materials. This could easily become a model for the UK too. By getting this done early, we are prepared and potentially open new or keep open existing markets. 

End-of-waste will only apply to the best quality material, as we are proposing the EN 643 standard which allows for a maximum of 1.5% contamination and zero hazardous material. In countries such as France, Italy and Spain where they already have end-of-waste, this is the standard that has been used. 

Other countries have it to some degree too with states and regions of Germany and Belgium allowing end-of-waste, although this is not currently at a national level. The Netherlands is also considering an application from the Dutch Federation of Recovered Paper Industry.

However, existing trade of material that does not meet these circular product standards will continue as before.

It is likely to be an exercise that takes time, not least because there will need to be discussion with organisations such as the Confederation of Paper Industry (CPI) that believes end-of-waste begins at the pulping stage. Of course, this would mean that exports could never qualify for these circular product criteria. 

We’ll engage in constructive talks with the CPI and seek to find solutions. 

Of course, I’ll keep you updated on how we are progressing with our application.