Flanders as a Guiding Country: A Single Portal for Plastic Recycling Doesn’t Always Make Things Easier

In the Netherlands, recycling companies often find themselves lost in a maze of bureaucracy and regulations to apply for so-called "end-of-waste" status, which is necessary to sell recycled materials as raw materials. They must demonstrate that their waste can be safely used in products, yet even when granted, this status lacks a legal foundation and doesn’t provide certainty.

Different but Not Easier

In Flanders, this is known as a "resource declaration." "In Flanders, it’s different, but it’s certainly not easier to apply for a resource declaration here," says Caroline Van der Perre, director and co-owner of the rapidly growing Flemish recycling company RAFF Plastics and board member of Denuo, the Belgian federation for the waste and recycling sector. According to her, it’s definitely not a matter of just a few clicks on a website.

Flanders is Stricter

RAFF Plastics processes plastic waste into granules used by clients to make laundry baskets, buckets, or flowerpots. They also collect masks, bags, and hoses from hospitals, later producing new wall coverings for hospitals from the processed materials. The company only applied for its first resource declaration after an environmental inspection revealed that the plastic flakes it was transporting fell under waste rather than raw materials. RAFF Plastics was issued a citation and had to apply for a resource declaration from the Public Waste Agency of Flanders (OVAM), the central authority in Flanders for sustainable waste and materials management. This was challenging. "It all starts with the question: what is waste? That needs to be more clearly defined at a European level," says Van der Perre. "Currently, the strictest country’s regulations apply. Flanders is stricter than the Netherlands. So, it’s not easier here."

Dutch Status Doesn’t Count in Belgium

Her company purchases plastic refrigerator waste from the Dutch recycling company Coolrec, part of Renewi, which has received an end-of-waste status for this purpose. "We make granules through mechanical recycling, cleaning it without adding anything, yet we can’t automatically use this material as a raw material. The Dutch end-of-waste status doesn’t count in Belgium," says Van der Perre. For Coolrec's polystyrene granules, RAFF Plastics eventually obtained a resource declaration after new testing, allowing new plastic to be made from these granules, though not for food packaging.

A Learning Process

The company now has eight streams with a resource declaration, with samples regularly tested by the same lab. "This took us two years. It was a real learning process for both us and OVAM," she says. "Initially, our collaboration was challenging because OVAM had limited experience with resource declarations for plastics, and we didn’t fully understand the process. A site visit from OVAM to RAFF Plastics allowed us to showcase our production, waste streams, and labs, strengthening our collaboration."

Campaign for Recycling

In Belgium, recycled materials gain resource status if they’re immediately usable for final products. Besides resource declarations, RAFF Plastics also holds a waste permit, which is essential for a recycling company to accept waste for processing. Additionally, the company measures contamination levels of all incoming waste. RAFF Plastics is currently part of OVAM’s "Flanders Recycling Hub" campaign, spotlighting the high-quality recycling sector, sharing expertise with the market and industry peers.

Uniform Regulations

Van der Perre supports GCNE’s call for uniform regulations. Her company often encounters regulatory differences during cross-border transport. In Belgium, recycled materials may have up to 6% contamination, but in the Netherlands, it’s only 2%. "There are countless similar examples. Every member state has its own rules. It’s hard to comply as a recycling company. That’s why we need uniform rules," she states. "If a Dutch company obtains end-of-waste status for its material, we should also be able to use it in Belgium. Currently, that’s not the case."

Bankruptcies

RAFF Plastics is also facing competition from cheap new plastic made from oil in China and the U.S. At these low prices, recycled plastic can’t compete. In the Netherlands, several companies have gone bankrupt due to this, including Umincorp. "That hit me hard. Previously, cowboy operations would go bankrupt, but now companies like Umincorp are going under," she says. The Netherlands aims to introduce a recycled plastic mandate by 2027, while Belgium’s target is 2030. "It’s tough. We’re all hitting the brakes, stopping investments, and trying to survive until 2030," says Van der Perre. "This leaves too much waste in the market. Without support, we risk losing Europe’s lead. Companies like ours receive EU subsidies to invest. If you want a circular continent, why let it fall apart due to cheap new plastic entering Europe?"

Control on Recycled Materials from Asia

In addition to cheap new plastic, the EU also imports cheap recycled materials from Asia with minimal oversight. Van der Perre states, "Resource declarations professionalize our sector, which is crucial for public health. However, the EU should control recycled materials from Asia as strictly as we’re monitored. This discrepancy makes plastic recycling increasingly difficult. It’s unfortunate because the alternative is incineration."

About This Series

The Dutch platform Green Chemistry New Economy (GCNE) aims for circular chemistry with innovative technologies, free from fossil fuels and carbon emissions by 2050. Plastic recycling plays a vital role in this vision. Too often, recycled materials are labeled as waste, and due to contamination, they can’t be used in food applications. In the Netherlands, recycling companies must apply to one or more of the 28 environmental agencies to gain end-of-waste status. Additionally, the Human Environment and Transport Inspectorate conducts inspections. In Flanders, there is only one central agency, OVAM, responsible for issuing resource declarations.

GCNE calls for a paradigm shift: assume that everything is a resource unless a decision tree reveals it should be considered waste. A uniform EU approach, based on international ISO standards, should be implemented, with a single resource declaration portal in each country.

This is the first article in a three-part series on this topic.

[Read part 2 on Renewi's approach here.]

[Read part 3 on OVAM's role here.]

Further insights will be covered at the Transition to Circularity network event, co-organized by GCNE, Circular Plastics NL, and Biobased Circular. For event details on November 7, click here.

This article was originally published in Change Inc, editor André Oerlemans.