Dutch Waste Management Association (Supplementary) (BTW0001)
European platforms and organisations
North Sea Resource Roundabout
The UK is an important partner in the North Sea Resources Roundabout. Within the context of the NSRR the UK, The Netherlands, Flanders and France aim to boost Circular Economy in the North Sea region by facilitating transboundary trade and transportation of secondary resources. Also with an eye to post-Brexit trade relations, our cooperation in this field is of great value to companies whose circular business cases rely on international flows of secondary resources.
EuRiC
The European Recycling Industries’ Confederation (EuRIC) is a natural supporter of the Circular Economy since recycling enables the economy to be circular by turning waste into new resources.
Recycled materials need to be readily available to substitute primary raw materials and bring substantial environmental benefits in terms of CO2 and energy savings. As primary raw materials, secondary materials are commodities which are priced and traded globally. Hence, the circular economy does not stop at European borders but is global in essence.
EuRIC takes an active role in ensuring that markets for recyclers within Europe and beyond remain open to foster the well-functioning of the recycling industry. A great example is the Green Deal, North Sea Resource Roundabout, which facilitates the cooperation within the countries in Europe.
Beyond Europe, import restrictions of certain types of waste announced by China poses a problem since it will likely also impact quality secondary raw materials meeting industry specifications or European standards and for which supply exceeds the demand in Europe, including in the UK. The example demonstrates already the importance of safeguarding free and fair trade for secondary raw materials which is instrumental to the growth of the recycling industry and the achievement of sustainable goals.
CEWEP: ‘CEWEP hopes that Brexit will not water down environmental standards, which would be the case, for instance, if RDF/SRF that is currently shipped from the UK to state-of-the-art Waste-to-Energy plants in the EU for environmentally sound treatment and energy recovery, would be landfilled instead.’
ITAD, GERMAN EfW sector
ITAD fully supports the CEWEP-statement.
Additionally, ITAD hopes that the constructive and pragmatic discussions and reasonable cooperation models between UK´s and Germany´s waste management sector with the aim of an environmental friendly, efficient and sustainable use of the resource waste will continue after Brexit.
German (BDE) Waste Management Association
German (BDE) Waste Management Association
The most important aspect for us in the Brexit debate is the potential impact of the UK exit on trade in waste between the UK and the EU and on waste shipments (especially RDF, waste code 19 12 12) from the UK to the EU in particular.
Whilst these shipments will remain legally possible as the UK is subject to the OECD decision, imports of RDF into the EU will, in the case of a „hard Brexit“, become more costly and more bureaucratic. „Hard Brexit“ in this context shall mean that the UK would leave the EU Customs Union without a free trade agreement in place. This would entail that customs law and procedure became applicable to all imports of goods (waste = goods) from the UK.
This would have particular impact on RDF imports. RDF would have to be classified as „municipal waste“ under Combined Nomenclature code 3825.10.00. For third country imports of these goods the EU currently applies a conventional rate of duty of 6.5% (also valid for 2018). This is an ad valorem duty and the exact amount will in each case be calculated on the basis of the customs value of the goods. In most cases the customs value is identical to the purchase price. Hence, the EU buyer would have to add costs for import duty in the amount of 6.5% of the purchase price on top of the latter, which would make RDF from the UK significantly more expensive. Other administrative customs fees could be applicable but we believe these will be rather minor.
It is thus in our common interest that some kind of trade agreement, preferential duty rates will be negotiated between the UK and the EU in order to avoid the above-described duty rate on imports of RDF into the EU.
EU import and export (tariffs)
CODE 382510/ waste
Import in EU
| Export from EU
| ||||
Country | Duty | Explanation | EU | MFN | GEN |
Norway Iceland
| 0% 0%
| European Economic Area
| 0% | 0% |
|
Turkey | 0% | Customs Union Duty | 0% | 6,5% |
|
Ukraine | 0% | Tariff preference and GSP* | 0% | 0%* | 0% |
Swiss Albania Montenegro Bosnia Macedonia Serbia
Morocco Egypt Tunisia South Africa | 0% 0% 0% # # #
0% 0% 0% 0%
| Tariff preference | 0% 0% 0% 0% 0% 0%
0% 0% 0% 0% | 0% 0% 5% 6,5% 25% 30%
2,5% 5% 0% 0% |
|
Uganda India Indonesia | 0% 0% 0%
| GSP |
| 25% 7,5% 5% |
|
Lybia | # |
|
| 5% |
|
Kenya
| 0% | Economic Partnership Agreement and GSP |
| 25% |
|
USA Russia China Ecuador Iran # | 6,5% | Third country duty
|
| 0% 5% 6,5% 10% 55% |
30% 10% |
United Kingdom |
6,5% |
In case UK/EU no deal |
Tariff depends on UK (without deal) | ||
# unknown
* GSP http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=uriserv:OJ.L_.2012.303.01.0001.01.ENG
Most Favoured Nation (MFN) rates stand for the regular customs tariff rates applicable to all countries. Conventionally applied between WTO members, these rates may also be applied between countries that are not members of the WTO. Preferential rates may be granted under free trade agreements or the Generalised System of Preferences (GSP).
The General Rate (GEN) is applicable to all goods not originating in countries falling under the MFN treatment or to goods of unknown or doubtful origin.
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