The Recycling Association says End-of-Waste is about circular product standards and should not be imposed at point of recycling

Cardboard recycling

The Recycling Association has said that it disagrees with the Confederation of Paper Industries (CPI) on the point at which End-of-Waste should apply.

In a position paper, CPI has reaffirmed its viewpoint that End-of-Waste should begin at the point of recycling.


But The Recycling Association has warned that this will prevent the adoption of circular product standards and stop the UK from treating the highest specification material as a commodity rather than a waste.

The Recycling Association chief executive Paul Sanderson said: “The Recycling Association strongly disagrees with the Confederation of Paper Industries that End-of-Waste begins at the point of recycling. 

“The UK market relies hugely on the export market with UK paper and cardboard mill capacity approximately half of what we consume. Much of that fibre is coming from mills abroad to cover the products we buy that are manufactured in Europe and Asia.

“Putting End-of-Waste at the point of recycling means effectively excluding the export market from End-of-Waste and means exporters cannot take advantage of low-burden movement of material. Of course, this benefits CPI members and reduces competition.

“End-of-Waste for paper and cardboard will mean we have the opportunity to produce the highest circular product standards enabling mills to choose whether to purchase this circular product or continue to buy under existing rules. Some of our European neighbours such as France, Italy and Spain have introduced End-of-Waste for paper and cardboard, and there are moves across Europe to introduce it. We should not be left behind in the UK. 

“We support efforts to move towards End-of-Waste and are actively pressing for it to happen in the UK for paper and cardboard with other supportive parties. This will allow seamless trade of circular paper and cardboard as a product rather than as a waste material. There will still be the option for trade under the existing system for those that want it. 

“Introducing circular product standards ensures we make paper and cardboard a commodity rather than a waste, and will benefit both the mills that will buy it and those that collect and sort it as a commodity grade. It will also reduce the burden on UK environment agencies who will see a commodity being exported allowing for more focus on illegal export by criminal gangs. 

“It is disappointing that CPI refuses to accept principles of free trade and circular product standards when it comes to paper and cardboard, but I’m confident that we will eventually introduce End-of-Waste circular product standards in the UK.”