European Commission proposal for a Directive of the European Parliament and of the Council amending Directive 2008/98/EC on waste (parts concerning food waste and textile waste):
It is absolutely crucial that the Czech Republic demands everything that will enable it to meet all of its ambitious circular economy goals. One of the prerequisites, in addition to the stability of the legal environment, is the request of the CCAEB that the Ministry of the Environment, at this stage of preparation of the key amendment to the European Directive for the circular economy , requires the European Commission to submit the main principles of the announced future delegated acts, or implementing regulations - a kind of "European implementing decrees". We welcome the qualified opinion of the Ministry of the Environment of the Czech Republic that the proposed 2030 targets for food waste are too ambitious and that, as far as the stages of the food chain are concerned, it is appropriate to have one common target for all stages of the food chain for the sake of simplification.
Regarding extended producer responsibility schemes for textiles and footwear - we fully support the intention of the Ministry of the Environment to have producers and importers of textiles, footwear and other textile-related products in Europe cover the costs associated with the further management of these commodities - the so-called extended producer responsibility - EPR. In addition, the Czech Association of Circular Economy asks to add wording concerning e-shops: this provision will also apply to e-distribution, as direct distribution from any country (not only from the Far East, but also from EU member states that only act as a transhipment point for goods).
Another key point concerns the European Commission's stated deadlines for transposition of the Directive: the MoE calls for at least three years, compared to the EC's proposal to have only 30 months for transposition.
The CABH proposes that the transposition period should be 4 years.
The CAB doubts that the application of the re-use principle to textiles and footwear in particular would reduce the impact on the budgets of states, municipalities and cities.
