The Executive Director of the ČAObh, RNDr. Miloš Kužvart, provided the magazine Odpady with a commentary on the new draft Waste Act and mentioned its main pros and cons in his answers.
What do you see as the main advantages of the new draft Waste Act?
The main good thing about the Waste Bill is that it has been tabled at all.
What do you see as its main disadvantages?
As to its "cons": it is pointless to criticise the Ministry of the Environment for not attaching implementing regulations to the proposal. This would deny the logic of this stage of preparation, where the inter-ministerial comment procedure will cause a number of changes to the proposal. Then the implementing regulations would often not be linked to the final text of the proposal and would be useless.
However, major stakeholders, including the ministries involved, had already raised concerns many months ago about the lack of communication from the start of the drafting of the new laws. Then the repeated comments concerning the absence of implementing regulations would not have been so frequent. It would simply have been more or less clear to everyone how the Ministry of the Environment planned to set up the implementing regulations. Now many entities are rightly concerned that the form of government decrees or regulations is something like a "Black Box" from which anything can "fall out".
However, our main reservation concerns the failure to use all the possibilities of CEP implementation: the failure to use the normative instrument (postponement of the ban on landfilling of usable waste, which has already been enacted for the fifth year, for another 6 years), the failure to use the application of economic instruments, which is so much recommended (also by the European Commission) (the increase in the landfill tax is too slow to help divert waste from landfills and increase recycling).
There is one "Collateral Damage" associated with this, caused by the aforementioned shift of the ban: the loss of confidence of the business sector in the stability of the legal environment of the Czech Republic.
Industrial waste processing is a modern and dynamically developing sector in the civilised world, and by promoting outdated methods of waste management, it undermines competitiveness and GDP generation in this entire modern segment.
Among other things, it is also a source of secondary raw materials that we will "store in the trenches" and import for expensive money for the needs of industry.
In any case, let me conclude by expressing the hope that during the next legislative process, the 850 major comments that have been received at the Ministry of the Environment will be resolved in favour of supporting the Czech Republic's transition to a circular economy. Otherwise, all of this is just political proclamations, and after years of waiting for a modern waste law, our Republic certainly does not deserve that.
