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End-of-Waste

The European Commission is working on new criteria under the Waste Framework Directive, known as end-of-waste criteria, to determine when textile waste ceases to be waste and can instead be treated as a secondary raw material. Properly designed rules can support industrial transition. Poorly designed rules risk slowing down the development of advanced textile recycling in Europe – which is now at risk of becoming the case.

Background

The circular transition takes place where Europe’s industry already exists. As existing production systems are developed to use resources more efficiently, new material flows and processes emerge. In that context, regulatory frameworks that reflect industrial reality are essential.

The current proposal from the European Commission’s research service, the Joint Research Centre (JRC), means that textiles would be classified as waste throughout the entire recycling chain and would only cease to be waste once finished textile pulp has been produced. This would mean that Södra Cell in Mörrum would be classified as a waste treatment facility, which is incompatible with the industrial operations carried out there. In practice, the JRC proposal could therefore result in Södra being forced to discontinue textile fibre recycling.

Our work

Since 2019, Södra has developed OnceMore – an industrial process that recycles blended textile materials at scale.

The process works as follows:

  • Natural fibres such as cotton are separated and converted into high-quality textile pulp.
  • Polyester, for which no industrial fibre-to-fibre solution yet exists, is recovered as energy within Södra’s integrated system.

This makes recycling both technically and economically viable and creates genuine circularity on an industrial scale.

However, under the current JRC proposal, the entire process would be subject to waste legislation, including the energy recovery that is necessary for the system to function. This could make OnceMore impossible to operate under existing permits – despite the process directly contributing to the EU’s climate and circularity objectives.

Positive elements in the proposed regulatory framework

Södra welcomes several aspects of the EU’s work and sees them as important for strengthening circularity:

  • A focus on increased circularity in the textile sector
    The EU’s ambition to steer textile flows towards more recycling is fully justified, particularly in a sector where the potential climate benefits are significant.
  • Clearer quality requirements at earlier stages
    Requirements for sorting, quality assurance and traceability early in the value chain strengthen confidence in recycled materials and improve material efficiency.
  • Harmonised regulation across the EU
    Common criteria reduce the risk of national differences and create better conditions for investment in industrial scale-up.

Risks in the proposed regulatory framework

At the same time, Södra sees several significant risks that could hinder Europe’s circular transition:

  • The end-of-waste point is placed too late in the process
    When textiles are regarded as waste all the way to finished textile pulp, functioning recycling processes are reclassified as waste management, despite material recycling being the primary purpose. This risks stopping established technologies such as OnceMore.
  • Energy recovery may be misclassified as waste incineration
    In OnceMore, energy recovery is used solely for the polyester fraction, where no industrial fibre-to-fibre technology yet exists. Equating this with waste incineration overlooks the fact that the process is recycling-driven and system-integrated.
  • Innovation risks being stalled before scaling up
    If legislation only allows the fully developed, ideal end solution from the outset, promising innovations risk being obstructed rather than allowed to develop and improve over time.
  • The textile sector is treated more strictly than other material streams
    For example, paper recycling allows recovered paper to be regarded as a secondary raw material at an early stage. Treating textiles more strictly creates imbalance and risks reducing competitiveness.

Our position

Regulations need to reflect how circular industrial flows actually work. Innovation happens step by step. The EU’s decision will show whether it wants to enable circular innovation within existing industries – or whether promising solutions risk being stopped by a regulatory model that does not take industrial reality into account.

Södra proposes two adjustments to ensure the framework works in practice:

  1. Place the end-of-waste point earlier, after sorting and quality assurance ahead of chemical recycling.
  2. Allow energy recovery of non-recyclable fractions when the primary function is high-quality material recycling.

This is not about exemptions – it is about creating the conditions for the EU’s circularity ambitions to become reality.

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