EU Recyclers’
Manifesto: Increasing
circularity in theconstruction sector
Re-constructing Europe.

EURIC'S 5 RECOMMENDATIONSFOR A CIRCULAR AND
SUSTAINABLE CONSTRUCTION
SECTOR
Construction and Demolition Waste (CDW), including concrete, wood, metals,bricks, glass, and plastics, makes up about 40% of all waste generated
annually in the EU, representing a major material stream. The construction
sector also significantly impacts the environment, contributing around 12% of
the EU's greenhouse gas emissions.
The sector faces substantial challenges in adopting circular economy practices.
Inefficient waste separation at construction works hinders material recovery andreuse, with much of CDW currently used for backfilling but still classified asrecycling. Often, CDW ends up in landfills, worsening environmental degradation
and resource depletion. Despite relatively high recovery rates, Europe’sconstruction sector needs to be even more ambitious in recycling to fully embrace
the circular economy. The focus should be on stimulating the market for recycledmaterials, to incentivise recycling efforts.
Despite the challenges, CDW presents a clear opportunity to increase circularity inthe sector. Using recycled materials from CDW can conserve resources like sand,gravel, and aggregates, mitigating negative impacts on air, noise, and climate. Every
ton of recycled construction material reduces the demand for landfilling or
backfilling, reducing the need for scarce backfilling and landfilling capacities.
A thriving recycling sector supports the EU’s climate neutrality goals, ensures
strategic raw materials autonomy, fosters innovation, creates jobs and drives
economic growth.

To enhance circularity in the EU construction sector, it is crucial to expand themarket for recycled CDW materials, which is currently limited. A robust European
regulatory framework that encourages the use of CDW in construction ispivotal in developing a market for recycled materials in the EU.

Key legislative measures include prioritising recycledmaterials in public construction projects throughGreen Public Procurement (GPP), promoting
standardisation for circular materials and products,
ensuring recycled resources are reflected in
Environmental Product Declarations (EPDs) used in theconstruction sector, improving selective demolition
practices, establishing clear EU End-of-Waste criteria
for CDW, mandating recycled content in construction
products, and aligning recycled materials with existingchemicals legislation.

EuRIC’s Construction and Demolition Branch (ECDB),
which comprises of national recycling federations
active in the collection, recycling and trade ofconstruction and demolition materials, can play a keyrole in realising the potential of CDW. ECDB supports
the development of industry standards and advocatesfor policies that drive demand for recycled materials in
the EU. As producers of recycled resources, EuRIC’s
ECDB members actively contribute to the EU’s
decarbonisation efforts.
In this Manifesto, EuRIC’s Construction andDemolition Branch presents 5 five key policy
recommendations for the EU’s 2024–2029 mandate
to increase circularity in the construction sector.

DRIVING CIRCULARITY IN CONSTRUCTION
THROUGH ENVIRONMENTAL PRODUCTDECLARATIONS (EPDS)
To advance our goal of greening the construction sector, EPDs will play acritical role.

EPDs provide clear information on a
product's environmental impact
throughout its lifecycle, including
essential documentation andcertificates. They help stakeholders
make informed choices and promotesustainable practices. Whilecurrently voluntary, EPDs areexpected to become mandatory forrecyclers where end-of-waste
criteria have been established,enabling market access.
Accurate EPDs are crucial; inaccurate
declarations could prevent products
from being sold. As EPDs become
more widely used, it's essential forrecyclers to engage early in theirdevelopment. Beyond carbon
reduction, EPDs should alsoemphasise other circularity benefits,
such as reducing resource extraction,
minimising landfill waste, preserving
energy, etc., to fully support recycling
efforts.
Therefore, developing robust criteria
for EPD declarations is essential.

ENHANCING C&D WASTE SEPARATION TO
INCREASE RECYCLING
The EU Commission shall establish specific CDW recycling targets under
the Waste Framework Directive (WFD) as of 2025. However, EuRIC’sConstruction & Demolition Branch (ECDB) is concerned about theinadequate implementation of current targets.
A recent JRC report highlights CDW's substantial potential for reuse andrecycling, but stringent technical standards for energy conservation and noise
insulation make reuse impractical for new buildings.
Recycling and selective demolition, however, present promising avenues
for improving C&D circularity. Setting specific targets for different types of
C&D waste will revolutionise the demolition industry, despite likely increases inoverall costs. The demolition sector has already invested heavily in labor andmachine safety, with a focus on reducing manual labor. While demolishers arewilling to separate various types of waste (wood, plastics, metals, sheathing,hazardous waste, and gypsum board) from the mineral fraction on-site, there
is resistance to separating concrete from brick-built structures.
ECDB aims to enhance recycling by promoting selective demolition toimprove the quality of materials for recycling. Selective demolition, which
effectively separates unwanted fractions, leads to higher quality recycled
aggregates that can be reused in both structural and civil engineering.
Whenever technically possible and economically reasonable, undergroundstructures, foundations, and concrete structures should be demolishedseparately to produce high-quality recycled aggregates suitable for new
recycled concrete. Similarly, above-ground portions of buildings could also be
selectively dismantled to yield mixed recycled aggregates appropriate for use
in infrastructure projects and as backfill or subgrade material for yards, anapproach already implemented in practice.
EuRIC also advocates that backfilling
CDW should no longer qualify as
recycling. Effective separation of C&D
waste is essential to increase recycling
rates. ECDB calls for clear targets andpre-demolition audits to ensure proper
sorting and recycling of materials like
concrete, metals, and wood, thereby
minimising waste and maximisingresource recovery.

ESTABLISHING END-OF-WASTE CRITERIAFOR CDW
Transporting recycled materials should be seen as transporting valuable
resources, not waste.

Introducing EU End-of-Waste (EOW)
criteria is crucial to enhance trust andacceptance of recycled materials from
CDW by builders and authorities.
Harmonising these criteria withestablished national standards will
promote the uptake of recycled C&D
materials in new construction projects
and facilitate the substitution ofextracted raw materials.
A European EoW Regulation would
further secure the market for recycled
C&D materials, simplifying their
movement across the EU. Suchregulation could not only boost
acceptance and demand for recycledmaterials but also align with existing
national EoW regulations in certain EUcountries.
This would ensure clear and consistent
rules regarding the transition ofmaterials from waste to product andtheir subsequent usage.

PROMOTING CIRCULARITY IN THE CONSTRUCTION
SECTOR THROUGH MANDATORY USE OFRECYCLED MATERIALS
To advance circularity in the EU construction sector, it is imperative tomandate the use of recycled materials in construction products under EU
legislation.

Currently, the market fails to sufficiently secure the uptake of recycledmaterials even though they match the quality and performance of primaryconstruction materials and offer greater environmental benefits. EU legislationmust drive demand for recycled materials from CDW providing stability andinvestment security for recyclers to expand capacities across the EU.
Only through mandatory tools can a robust market forrecycling C&D materials be ensured, fostering a shift towards
increased circularity in construction.
Additionally, swift development of Green Public Procurement (GPP) criteria
for recycled materials from C&D at the EU level is essential. The public sector,responsible for a significant share of construction industry purchases andrevenues of some of the most energy-intensive construction industries (i.e.
concrete), plays a pivotal role in decarbonising the sector. However, GPP
practices are currently fragmented within and across Member States,
limiting their potential.
Establishing mandatory EU criteria through the Construction Products
Regulation (CPR) presents a crucial opportunity to drive widespread demand
for sustainable construction products in Europe. Collaboration with national
environment and infrastructure ministries is vital to aligning these efforts
across all levels of governance.

BALANCING CHEMICALS LEGISLATION:
ENSURING COMPLIANCE WITHOUT HARMING THE
CIRCULAR ECONOMY
Ensuring the protection of human health and the environment isessential for ECDB recyclers.
Compliance with EOW and productrequirements is essential for meetingcustomer demand and ensuring safety.
Properly defined thresholds for chemicallegislation (e.g., POP and PFAS regulations),
technically feasible rules, and manageable
compliance costs are essential.
Legal clarity and economic profitability are
crucial, especially for the small and mediumsized enterprises that form the backbone ofthe CDW sector.
Fair competition between recycled CDW
and primary materials is vital. Excessive
health and environmental requirements on
recycled CDW could hinder recycling andincrease landfilling.
The potential requirement to register
recycled aggregates under REACH raises
economic feasibility concerns and could leadto increased landfilling if not balanced withthorough economic, environmental, andsocial impacts assessments.
ECDB advocates for chemical regulations
that facilitate a circular economy without
imposing undue economic burdens on
recyclers.

Excessive health and environmental requirementson recycled CDW could hinder recycling andincrease landfilling

EuRIC, the European Recycling Industries’ Confederation is theumbrella organisation for the recycling industries in Europe.
Through its 75 members from 23 European countries, EuRIC
represents more than 5,500 large companies and SMEs involved in
the recycling and trade of various resource streams. They represent
a contribution of 95 billion EUR to the EU economy and 300,000
green and local jobs.
By turning waste into resources, recycling reintroduces valuable
materials into value chains over and over again. By bridgingcircularity and climate neutrality, recyclers are pioneers in leading
Europe’s industrial transition.

ECDB, EuRIC's Construction & Demolition Branch was founded in2023, following the Metabuilding project's conclusion, in response
to growing demand and markets for recycled aggregates andother C&D recycling products in Europe. ECDB contributes toachieving the EU's climate and environmental objectives.
ECDB represents the European construction and demolition waste
recycling industries to European institutions and collaborates withother European and international stakeholders, supported by otherEuRIC branches.

EuRIC
European Recycling Industries’ Confederation
Boulevard Auguste Reyers 80, 1030, Brussels,Belgium
T: + 32 485 97 08 71
Email: info@euric.org
www.euric.org

Find us on:
linkedin.com/company/euric-recycling@EuRIC_Recycling