The Impact Assessment Institute (IAI) scrutinised the European Commission’s Impact Assessment, Additional Analysis and background data for the Circular Economy legislative package. The Commission uses a highly developed “European Reference Model on Waste” to evaluate the costs and benefits at EU and Member State level of waste management scenarios. However, the Institute concludes that the model’s application undermines its value as a tool for policy making.
The model is not fully available to stakeholders and it is not possible to scrutinise its algorithms and understand its calculation methods. Full public availability of the underlying calculations is the appropriate benchmark for policy making in such a prominent domain and would support greater confidence in the resulting policy conclusions.
The costs and benefits of the scenarios calculated by the model were not consistently taken into account in the setting of EU legislative targets. Further, the costs and benefits for Member States do not give a coherent indication whether the scenarios could feasibly be implemented. The individual Member State targets for recycling and landfill do not reflect feasibility, risking them not being met in practice.
The IAI proposes a new method for calculating individual targets for recycling and landfill, tailored to the conditions in each Member State. By taking into account the percentage for recycling and landfill in the baseline year as well as GDP per capita, feasible targets can be calculated for each Member State. A spreadsheet to calculate targets according to varying parameters has been published along with the IAI’s study. The IAI invites all stakeholders to assess this option critically.
IAI Chairman and Managing Director Simon Godwin said: “The Impact Assessment Institute found that the Commission’s model for supporting waste policy is not fully transparent. Our scrutiny further concluded that the crucial factor of ‘feasibility’ was not addressed. We decided to propose how feasible targets could be developed and we offer this as a resource for ongoing policy making.”