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The European Business Association appealed to the authors of draft law \u21162207-1-d “On Waste Management” for it to be revised before the second reading. For many years, the EBA experts have been involved in the development of waste management reform in Ukraine, which is progressing at a rather slow pace. Consideration of the framework draft law \u21162207-1-d is constantly postponed, and the latest version of its text for the second reading has not yet been officially published. <\/p>\n
In view of this, the EBA calls to speed up the revision and adoption of draft law \u21162207-1-d, as well as to involve the business community in its discussion at the meetings of the Verkhovna Rada Committee on Environmental Policy and Nature Management before voting on the second reading.<\/p>\n
The EBA experts familiarized themselves with the final text of the draft law which was received in working order, and express gratitude both for the opportunity to do so and for having some of their proposals considered (for example, excluding the provisions about the replacement of the extended producer responsibility system with the introduction of environmental tax). At the same time, the business has a number of comments and suggestions to the current text of the document concerning the EPR system, the waste transfer ownership, the powers of local governments, the definition of certain types of waste, and more.<\/p>\n
The EBA member companies pay special attention to issues related to industrial waste management. Business welcomes the decision to exclude scrap metal operations as a valuable raw material for the Ukrainian industry. However, the concept of “metal waste”, which has appeared in the wording of the document, may lead to differences in the interpretation of legal norms by permitting and controlling authorities. Thus, they may attribute scrap metal to “metal waste”. A similar problem may arise with the simultaneous application of different legal requirements for by-products of ferrous metals (slag, sludge, scale, scrap, etc.), so it would be appropriate to remove them from the draft law, of course, provided they meet the established requirements for products.<\/p>\n
When establishing a general framework for waste management, the new version of the draft law does not always take into account the specifics of industrial waste. This relates, for example, to the issues of pre-storage of waste, responsibilities of generators of such waste, requirements for the disposal of industrial waste at landfills, etc.<\/p>\n
Also, the draft law currently lacks effective incentives for companies that use secondary raw materials instead of primary resources. Although the document could outline the priority of secondary raw materials over primary according to the concept of the circular economy.<\/p>\n
The consideration of these comments is important for building the effective operation of EPR, industrial waste management, and the development of closed-loop principles based on the harmonization of Ukrainian legislation with European practices. Therefore, the European Business Association hopes for the revision of draft law \u21162207-1-d before the second reading with the participation of community representatives. At the same time, given the extreme importance of the framework law, the EBA urges not to delay its consideration and adoption for further development of waste management in sectoral areas.<\/p>\n
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