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Why end-of-waste status should actually be called beginning-of-resource status
Why end-of-waste status should actually be called beginning-of-resource status

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Milgro

Reading time

3 minutes

Why end-of-waste is actually the beginning of raw materials?

Waste often sounds like something you just throw away, but what if that same waste is actually the beginning of a new resource? In a circular economy, nothing is really worthless. That is exactly what end-of-waste status is all about, a status that converts a waste into a reusable raw material. This process is in line with the ambition of the Netherlands and the EU to achieve a circular economy in which raw materials are constantly reused and almost no waste remains.

What is end-of-waste status?

End-of-waste status (also known as end-of-waste ) is the legal limit at which something that was initially considered waste, after a recovery or recycling operation, is no longer formally waste, but a product or secondary raw material with value(end-of-waste criteria). This is described in the European Waste Framework Directive.

According to this directive, something stops being waste when it meets a set of criteria, such as that the material:

  • has a particular beneficial use,
  • has a market or demand,
  • meets technical, environmental and health standards, and
  • does not cause adverse effects on the environment or health.

Take as an example old paper that is sorted, cleaned and reprocessed into new paper, at that point the material is no longer "waste," but a valuable resource that goes back into the production chain.

When does waste qualify as end-of-waste?

Not every waste stream automatically receives this status. EU rules stipulate that a waste can only receive end-of-waste status when it meets the conditions below:

  1. Technical suitability: the material must be technically suitable for reuse.
  2. Market acceptance: there must be an existing demand for the material.
  3. Legal applicability: the use of the secondary raw material must meet legal requirements.
  4. Safety: the reuse must have no demonstrable adverse effects on humans and the environment.

In the Netherlands, there is policy and recent reporting around how member states deal with these criteria and the procedures to demonstrate compliance.

Why it should be called beginning-resource

Here's where it gets interesting: a waste is often not an end point, but rather the beginning of a new circular value. The word "end" in end-of-waste status sounds like something stops. But in reality, it is the starting signal for reuse, innovation and value retention.

Companies in the field sometimes prefer to call this transformation beginning-resource status, because it changes the mindset from "throwing away waste" to "putting raw material to use." This is exactly what is needed for circular chains to grow: you not only have to recycle waste, you also have to legally and economically recognize it as a raw material.

A recent white paper by Dutch business associations highlights that as long as secondary materials are legally seen as waste, circular projects will not get off the ground properly which hinders innovation and market growth.

Why end-of-waste (beginning-of-resource) status is important in the resource transition

The resource transition is about closing material cycles and reducing dependence on primary raw materials. End-of-waste status plays a central role in this because it gives secondary raw materials market access and legal clarity.

Economic benefits: fewer imports of raw materials and lower production costs as secondary materials are competitively available.
Environmental benefits: reuse lowers carbon emissions and reduces landfill or incineration volumes.
Innovation: companies are encouraged to develop new uses for secondary raw materials.

Without a solid end-of-waste status, much of the reuse remains legally up in the air, slowing down chains and inhibiting investment.

Contributing to the resource transition? 7 ways to close the gap

Do you want to contribute concretely to closing the gap between waste and reusable raw material? Here are seven practical steps:

  1. Identify suitable waste streams within your organization that have the potential to become secondary raw materials.
  2. Document the quality of materials so that they meet technical and legal requirements.
  3. Work with certified recycling and processing partners so that the transition from waste to resource is easily traceable.
  4. Use and understand the EU end-of-waste criteria to guide your internal processes and compliance.
  5. Communicate internally and externally about the value of secondary raw materials and how you use them.
  6. Develop new applications or business models based on recycled materials.
  7. Measure and report your impact, how much primary raw materials have you replaced and how much carbon emissions are you saving?

By seeing waste not as a "burden" but as a source of value, you help not only your organization but also the entire economy to move faster towards true circularity, a circular economy in which raw materials are reused again and again, as the Dutch circular economy policy aspires to.

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