Letter on Notification of an Italian draft legislation establishing end-of-waste criteria for Solid Recovered Fuel (SRF)

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We are writing to express our concerns with regard to the notification of the Italian draft legislation n°2012/480/I relating to the production and condition for use of solid recovered waste.As highlighted below in more detail, Italy is classifying solid recovered fuel (SRF) as non-waste in order to be able to incinerate or co-incinerate it outside of the EU regulatory framework for waste and industrial emissions (incineration and co-incineration), arguing that SRF that is prepared and classified/specified according to Italian standard UNI EN 15353:2012 standard ”Solid Recovered Fuel” ceases to be classified as waste.
We strongly disagree with the end of waste criteria (EoW) proposed by Italy giving SRF a product/fuel status that does not take into account the negative environmental impacts as required by the Waste Framework Directive (WFD) Article 6.c.

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