Feedback from:
Bioenergy Association of Finland

Feedback reference

Submitted on
20 January 2020

Submitted by
The Bioenergy Association of Finland

User type
Business association

Bioenergy Association of Finland

Organisation size
Micro (1 to 9 employees)

Transparency register number

Country of origin

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