Industry reacts to EU end-of-waste criteria proposal

Aggregates Europe, Concrete Europe, EAPA, FEAD, FIR, Recycling Europe and FIEC issued the response on 8 September, following the publication of the revised JRC proposal on 12 June 2026.

The proposal defines when recycled materials stop being legally classified as waste and become usable products.

As construction and demolition waste accounts for around 25% of Europe’s total waste flow, the proposed rules are particularly important to the EU’s circular economy goals, the response stated.

It said that while the associations welcome the ambition to strengthen the circular economy, they believe the proposal “continues to raise significant and serious concerns.”

They warn that overly complex criteria could result in fewer materials achieving end-of-waste status, lower recycling rates, more usable material going to landfill and reduced investment in circular business models.

“EoW [end-of-waste] must contribute to simplification and market certainty. They should not add any additional regulatory layers that create new administrative burdens on materials that are already subject to extensive environmental, health and product legislation, especially as CDW recycling is mainly carried out by local or regional operators, many of which are SMEs and due to distance, cross border trade of recycled aggregates is minimal,” the statement read.

The associations said EU criteria should act as a common baseline or minimum safeguard, while allowing member states to retain national systems that reflect local geology, groundwater, climate and environmental conditions.

They also call for clarification that achieving EU end-of-waste status would be only one route for placing recycled aggregates on the market. Materials that retain waste status should remain usable where national rules currently permit this.

The industry groups concluded that the criteria must operate as an enabling tool rather than a new barrier to recycling.

They encouraged further technical dialogue on EU leaching limits, the relationship between end-of-waste rules and the Construction Products Regulation, double testing, regulatory overlap and scope restrictions that could affect established and innovative recycling routes.

They argued that simplifying the framework and preserving viable routes to market would be essential if the EU is to increase its circular material use rate from 11.8% to 24% by 2030.