Eurits' point of view

Our position papers all refer to basic conditions for a free market. The following conditions should apply to ensure that the (free) market can operate in an environmentally-sustainable way:

The waste hierarchy must be used with care
Using an earlier step in the waste hierarchy is always preferable, as long as all direct and indirect environmental and safety aspects have first been fully considered and it does not create more pollution than would have been the case by following a lower step in the hierarchy.

Good definitions of Waste and End-of-Waste (EoW) are adopted
Eurits strongly believes that a material should be defined as "waste" by reference to its physical and chemical properties, rather than any subjective criteria.

Hazardous waste should remain classified as waste and subject to waste regulations in any further uses or applications. The only possible exception could be where the waste undergoes a licensed treatment that separates the hazardous contaminants to allow its further use as a product.

Hazardous waste should not be declassified for use as an energy source, as this could lead to the emission limit values set out in the Industrial Emissions Directive being circumvented. Once a waste is declassified, then the emission limit value (ELVs) and Best Available Techniques (BAT) relating to waste will no longer apply and lower standards will come into force.

No solution by dilution
In waste management, the technique of ‘dilution’ is often used to try to circumvent environmental legislation. The objective of dilution is to allow a waste to be treated using a cheaper, but generally less environmentally-acceptable, solution. Such an approach is wrong and is prohibited under the Waste Directive [2008/98/EC].

Environmental protection is best served by waste materials being decontaminated and either destroying or concentrating and safely disposing of the toxic component. This is preferable to diluting and dispersing toxic components with potentially adverse impacts on human and environment health.

There should be full transparency and traceability
Eurits supports complete transparency and traceability in the waste management chain, from the waste producer to the final treatment of the waste.

In addition, Eurits supports an "open door" policy to the operational aspects of the waste management chain. The aim is to establish public confidence in, and acceptance of, our facilities.

Implementation of legislation and its continued operation should be enforced by the competent authorities

Eurits believes that implementing and operating legislation governing all forms of waste incineration - including co-incineration - and treatment should be firmly enforced by the competent authorities. This will ensure that the relevant legislation is applied consistently and effectively.

Application of consistent and uniform standards
Eurits supports application of strict standards and the use of BAT for all forms of waste treatment, and specifically for treating waste that is dangerous or hazardous, including high-temperature waste incineration. These strict standards should be applied uniformly and consistently throughout Europe, including all plants performing similar treatment of wastes, whether or not these are part of that plant's primary function.