Making waste work: RISERS and the future of EoW

From Linear to Circular: Rethinking Waste

The Circular Economy presents a transformative approach to production and consumption, emphasising the efficient use of resources, minimising waste, and maximising value throughout a product’s lifecycle.

In contrast to the traditional linear model of “take, make, dispose,” the circular model seeks to close material loops by reusing, recycling, and repurposing resources. This is particularly crucial in the face of growing environmental challenges, resource scarcity, and rising demand for sustainable solutions.

A significant yet often underutilised opportunity lies in the potential of waste streams, secondary raw materials, and industrial by-products, which can serve as valuable inputs for new products and processes.

Industrial Symbiosis: Unlocking the Value of Waste

Central to this concept is Industrial Symbiosis (IS)—a collaborative approach where the by-products, waste, or excess resources of one industry are utilised as inputs by another. This not only reduces environmental impact but also enhances resource efficiency and economic value across sectors. In an era marked by resource scarcity and environmental degradation, secondary raw materials, industrial by-products, and waste streams have not been used to their full potential. Unlocking this potential through circular practices and IS can foster innovation, strengthen supply chains, and drive sustainable growth.

Legal Frameworks and the Challenge of End-of-Waste

Under the EU’s Waste Framework Directive, a material is assumed to be a waste unless it qualifies as a by-product or meets the strict End-of-Waste (EOW) criteria. While this legal safeguard aims to protect the environment and human health, it also stifles innovation and slows progress toward a circular economy and IS.

The RISERS project will evaluate the process used to develop EOW criteria to explore how it could be adapted to support IS. The goal is to inform a roadmap for modifying the EOW methodology to better facilitate IS adoption.

By-Products vs End-of-Waste: Understanding the Criteria

End-of-Waste

EOW status allows a recovered material to shed its “waste” label and re-enter the market as a product.

By-products

These are materials unintentionally created during production but usable without further treatment.

The main criteria and delineating requirements for both by-products and EOW can be summarised in the table below:

By-product criteria (Article 5 WFD)	EOW Criteria (Article 6 WFD)
Produced as an integral part of the production process	–
Can be used directly without any further processing other than normal industrial practice	It has undergone a recovery, including recycling, operation and complies with specific criteria Complies with specific criteria
Further use of substance or object is certain	Commonly used for a specific purpose Market demand exists
Further use is lawful, i.e. the substance or object fulfils all relevant product, environmental and health protection requirements for the specific use and will not lead to overall adverse environmental or human health impacts	The use is lawful – The substance or object fulfils the technical requirements for the specific purpose referred to in (a) and meets the existing legislation and standards applicable to products; and The use of the substance or object will not lead to overall adverse environmental or human health impacts

Table: Comparison of criteria for By-Products and End-of-Waste

A Fragmented Landscape: Current State of EoW in the EU

Achieving End-of-Waste (EOW) status is a lengthy and complex process. To date, only three EOW criteria have been established at the EU level—for metal scrap, glass cullet, and copper scrap. While three additional streams—plastics, textiles, and mineral fractions of construction and demolition waste—are currently under development, no further EU-wide EOW criteria are planned at this time.

Individual member states have issued EOW criteria for various wastes, at various levels, such as state and country level, but these may not be recognised beyond the borders within which they are implemented.

Thus, the current state of EOW is fractionated and complex across the EU.

The RISERS Proposal: Standards over Bureaucracy

RISERS seeks to propose an alternative to the complex and time-consuming EOW processes through the use of standards. Standards would require waste to be treated to an already established level based on the input material standards for a production process. Thus, the requirements listed in the Table above would be embedded within the EOW standards.

In addition, specific policies relating to wastes would be referenced in these proposed standards. An overview of such policies can be found here (https://environment.ec.europa.eu/topics/waste-and-recycling_en).

Redefining Waste: A New Approach to Classification

The current Waste Framework Directive makes reuse difficult and onerous. Businesses must prove that a material isn’t waste. While the proposed Circular Economy Act aims to harmonise EOW criteria across the EU, there is little detail on how the process will be streamlined to make EOW more easy to implement.

RISERS is investigating the possibility of moving to a position where a substance or object is a resource first and only becomes a waste if it fails to clear criteria. This more flexible framework would:

Assume materials are products or by-products unless proven otherwise
Only classify materials as waste if no legitimate, lawful use can be found
Reduce bureaucratic delays for businesses engaging in circular practices

This approach would carry risk that must be minimised to ensure that the process cannot be exploited to allow a risk to health or the environment.

Horizontal and Vertical Standards: A Dual Structure

The initial proposal centres on the use of horizontal and vertical standards.

A horizontal standard would codify the structure of the vertical standards, including what parameters must be included (such as waste code, treatment methodology, standards that must be met to enable use as an input, what the input could be used for and quality assurance conditions).

The vertical standards would be for specific resources and address each of the requirements appropriate for that resource, based on the horizontal standard parameters.

Looking Ahead: A Roadmap for Change

While national and regional EOW schemes offer some flexibility (through position statements or case-by-case decisions), this is limited. With the EU unlikely to approve more EOW criteria in the near future, the RISERS roadmap proposes:

Legal clarity for businesses using recovered materials
Standardised technical specifications for safe reuse
A framework that enables—not restricts—IS

RISERS is launching a series of Working Groups, including one centred on EOW. The working group will expand on these initial ideas and develop the criteria for the proposed horizontal and vertical standards.

James Woodcock

International Synergies Ltd.