Brussels wants simpler rules before the shopping season starts. Three governments want the smallest sellers exempted from waste-management payments. Meanwhile, a new study finds Europe keeps adding waste-burning capacity even though existing plants could already burn far more rubbish than they receive.

“We need to have a simplification before the Black Friday shopping starts and the Christmas shopping,” Environment Commissioner Jessika Roswall said in her remarks before Monday’s Environment Council. The shopping season gives negotiations an immediate deadline, as businesses prepare to send packaged products across EU borders.

The Commission and the three governments (Austria, Czechia, and Estonia) agree that compliance should become cheaper and simpler. But their proposals go different distances. Removing repeated administrative costs would make existing obligations easier to fulfil. Exempting sellers from waste-management contributions would also remove part of their responsibility for the packaging they supply.

Italy brought a different concern to the same meeting: recycling companies are struggling to sell recovered plastic. Together, the discussions raise a question that extends beyond Christmas deliveries: how to ease the burden on businesses while ensuring packaging is collected, recycled, and paid for.

Relief for the smallest sellers

Austria, supported by Czechia and Estonia, presented a joint proposal addressing obligations that can apply even when a business sends only small quantities of packaged goods into another member state. These include national registration, contributions to packaging-waste schemes, and appointing a local representative.

“If even the smallest packaging quantities cause high costs and additional bureaucracy, something is going wrong,” Austrian Environment Minister Norbert Totschnig said in a statement ahead of the meeting. Austria argues that reducing packaging waste should not require disproportionate costs for small businesses.

The three governments want EU-based businesses supplying minimal quantities exempted from registration, participation in waste-management schemes, contributions, and the representative requirement. Those supplying slightly larger but still very small volumes would pay a simplified flat-rate contribution and would not need a representative. Their paper does not specify numerical thresholds.

They also propose a single European registration entry point and greater responsibility for online platforms, potentially allowing platforms to fulfil obligations for their sellers. Those changes could reduce duplication or move responsibility to another actor. The proposed financial exemptions go further: they would excuse eligible sellers from contributing. The paper does not estimate how much contribution income would be lost or whether other producers would have to cover it.

Recycled plastic without buyers

Italy’s paper to the Council focuses on what happens after packaging is collected. It describes weak demand for recovered plastic, plant closures, and sorting centres becoming congested. Collecting material separately cannot deliver recycling targets if processors lack buyers.

Rome wants stronger controls on imports, warning that virgin plastic can be declared as recycled. Its proposals include separate customs codes, certification, and traceability, alongside action against dumping or subsidies. Italy also wants recycled-content requirements extended to more products and public purchasing used to support demand.

The government seeks faster tax credits for recycling investment, energy-cost relief, and temporary support for difficult-to-sell mixed plastics. These requests address a different cost problem from the small sellers’ paperwork: keeping European recycling capacity commercially viable.

“Losing recycling capacity today means greater dependence on imported virgin polymers tomorrow”, the Italian paper warns. Its proposals show why packaging simplification cannot be judged only by sellers’ savings. The waste still needs an outlet, and recycling depends on businesses being able to process and sell it.

Incinerators with room to spare

Tuesday’s study by campaign group Zero Waste Europe questions investment in additional waste-burning facilities. Using 2022 data, it estimates EU incineration and co-incineration capacity at 198.4m tonnes, compared with 133.6m tonnes treated. That leaves almost 65m tonnes of unused capacity on paper.

The total does not mean every country has enough suitable facilities. Waste categories, plant capabilities, and location matter. The study’s central argument concerns the future: meeting Europe’s recycling targets would reduce the material left for burning. Author Dominic Hogg concludes that Europe would not need additional waste-burning capacity overall under the scenarios that meet its recycling targets. 

Operators emphasise that some waste cannot be recycled. In its July position on carbon-market reforms, the Confederation of European Waste-to-Energy Plants (CEWEP) described its role as treating “the non-recyclable waste streams, including rejects from recycling processes, that cannot be prevented or recycled”. That leaves a dispute over how much capacity will be needed as prevention and recycling improve.

We need to have a simplification before the Black Friday shopping starts and the Christmas shopping. — Jessika Roswall, Environment Commissioner

The study is not an assessment of the proposed exemptions for small sellers. It challenges the broader investment choices behind Europe’s waste policy. Before Christmas, governments face a decision over which packaging obligations to simplify and which contributions to retain.