No C 206/62 Official Journal of the European Communities 6. 8. 84 
environment and the Community's energy balance 
sheet means that this problem also acquires a Com­
munity-wide dimension. 
5. Inner-city and commuter traffic unfortunately 
accounts for 70 % of some road accidents, viz. 70 % 
of all accidents in which persons are injured take 
place in built-up areas, more than 70 % of all per­
sons killed in road accidents are not car occupants 
but either pedestrians, cyclists, moped riders or 
motor cyclists, and 70 % of all the fatalities are chil­
dren under the age of 18 or adults over the age of 65. 
Car occupants today are so well protected by seat-
belts and head restraints in urban traffic that they 
hardly suffer any injuries at all when involved in accidents. An optimum standard of safety is now 
provided for vehicles in urban traffic. 
6. The time has now come for the legislator to 
make the environment in which motor vehicles and 
pedestrians have to move about so safe that people 
who do not enjoy the protection of a car also have a 
better chance of survival. Imposing more severe 
fines and other types of penalties is no solution. The 
only thing which will help is to keep pedestrians 
and road traffic apart. 
7. The Economic and Social Committee reserves 
the right to deal with this question in greater detail 
at a later date, if it so wishes. 
Done at Brussels, 24 May 1984. 
The Chairman 
of the Economic and Social Committee 
Francis CEYRAC 
Opinion on the Community action programme on the management of waste (avoidance, 
recycling, disposal) Community waste management programme 
(84/C 206/18) 
A. LEGAL BASIS FOR THE OPINION 
On 26 October 1983, the Economic and Social Committee, acting under the fourth 
paragraph of Article 20 of its Rules of Procedure decided to issue an opinion on the 
abovementioned matter. 
Procedure: 
The Section for Protection of the Environment, Public Health and Consumer Affairs 
which was responsible for preparing the Committee's work on the subject, adopted its 
opinion on 26 and 27 April 1984, in the light of the report by Mr Kolble. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
At its 217th plenary session' meeting of 24 May 1984, the Economic and Social 
Committee unanimously adopted the following opinion. 
1. Scope of the study 
1.1. The volume of waste produced in the Com­
munity has been increasing steadily. Even if the 
economy remains stagnant in the next few years, the 
production of waste and its concentration in parti­
cular areas may increase further unless suitable, ade­quate counter-measures are taken. In addition, the 
pressing, intensified efforts to prevent pollution of 
the atmosphere and water will inevitably produce 
considerable quantities of various types of waste. 
1.2. This trend underlines the need for decisive 
Community action to tackle the range of problems it 
6.8.84 Official Journal of the European Communities No C 206/63 
creates and, in particular, the threat to the individual 
and the environment arising from the presence and 
concentration in some of these waste products of 
dangerous and toxic substances. 
1.3. The Committee feels that action is necessary 
in the following three areas: 
— avoiding or reducing as far as possible the prod­
uction of waste by re-using products and intro­
ducing low-waste technologies, for example, 
— making maximum use of unavoidable waste 
through recycling to obtain raw materials or 
energy, 
— disposing safely of unavoidable and unusable 
waste. 
1.4. A special type of measure must be taken to 
guard against the dangers of radioactive waste, 
which constitutes a special case, governed by the 
standards laid down in the Euratom Treaty, and 
need not be considered here. 
2. The effects of waste on the individual and the 
environment 
2.1. Waste can be a burden on the environment 
and endanger health when harmful substances, 
some of them long-lasting, contaminate by various 
means the soil, the water — and especially ground 
water - or the atmosphere. 
The traditional methods of waste disposal, namely 
tipping and dumping, can also harm the environ­
ment by taking up too large an area of land, or tak­
ing up land in the wrong place, and/or spoiling the 
natural countryside. 
2.2. Even the incineration of waste, which is still 
extensively used without the recovery of energy, in 
some parts of the Community, causes environmen­
tal problems, especially air pollution. 
3. Economic and social effects of waste management 
3.1. There is a direct link between the recycling of 
waste, on the one hand, and the conservation of raw 
materials and energy on the other. This link is parti­
cularly pronounced in the Community, which is one 
of the world's leading importers of raw materials 
and energy. 3.2. Consequently, any development and spread of 
new methods of recycling and processing waste is 
likely to lead to major savings in this area. 
3.3. The labour market aspect of this problem 
should also be emphasized here, since waste man­
agement involves a large number of companies 
which currently employ over two million workers; 
appropriate new moves in this area will therefore 
probably bring considerable benefits for employ­
ment in the Community. 
3.4. Finally, it should not be forgotten that sectors 
dealing with waste management could, by creating 
investment and increasing economic activity, 
become economic and social growth areas. 
4. Responsibility of the authorities and the public in 
waste management 
4.1. A reduction in the amount of waste produced, 
increased utilization of waste and the safe disposal 
of unavoidable and unusable waste can only be 
achieved if all private and public sector forces direct 
their behaviour towards these goals. 
4.2. In the private sector, this applies to all spheres 
of economic activity, including the individual con­
sumer. 
4.3. All public sector institutions and bodies must 
also be required to take account in the course of 
their activity of the general objectives set out above, 
especially when they are awarding major contracts. 
4.4. These objectives, i.e., the reduction, recycling 
and safe disposal of waste, must be borne in mind at 
an early stage in economic planning and in the 
drafting of programmes for all areas of policy which 
could have significant waste management implica­
tions. 
4.5. As it cannot bea assumed that all public and 
private sector forces will voluntarily adapt their 
behaviour to comply with the three waste manage­
ment objectives, the national authorities responsible 
for environment policy should introduce appro­
priate measures, including legislation and adminis­
trative action, to ensure that they do so. In so far as 
No C 206/64 Official Journal of the European Communities 6. 8. 84 
State measures are necessary, the Committee 
believes that preference should be given to those 
measures which will achieve maximum efficiency 
with a minimum of red tape. If a waste management 
objective can be achieved more easily by using mar­
ket mechanisms, government bodies should make 
use of this possibility. 
5. Priorities for a European waste management pro­
gramme 
5.1. The waste management measures of the Com­
munity and individual Member States have so far 
failed to place sufficient emphasis on reducing 
waste. The Committee believes that efforts in this 
area will have to be stepped up in the future. A cut­
back on packaging material coupled with increased 
durability for consumer goods would, for instance, 
have a major impact on the amount of household 
waste produced each year. Steps should also be 
taken to encourage the production of repairable 
products and in suitable cases of standardized prod­
ucts and spare parts. 
Where the generation of waste is unavoidable, 
attempts should be made to confine this waste as far 
as possible to what can be recycled in some way. 
The production of hazardous waste or waste con­
taining harmful substances should above all be kept 
to a minimum. 
5.2. Measures to increase utilization of waste 
should give greater priority than in the past to recy­
cling — thermal, mechanical or biological. Apart 
from household waste this applies in particular to 
the large quantities of agricultural waste. Import­
ance should also be placed on the use of sewage 
sludge for soil improvement. 
5.3. Even if greater efforts are made to reduce the 
amount of waste produced, and to increase recyc­
ling, considerable, quantities of waste will still 
remain, and its safe disposal will therefore continue 
to be an urgent necessity; the competent national 
authorities should always ensure that it is carried 
out according to the regulations in the interests of 
health and environmental protection. 
5.4. This is particularly true of the various types of 
hazardous waste, to which the national authorities 
and Community bodies should pay particular atten­
tion. 5.5. Derelict tips where dangerous waste has been 
dumped without the requisite safety precautions are 
a special problem. The Committee feels that these 
dumps should be listed systematically and closed 
off to access by unauthorized persons, in particular, 
children. The scale of any damage to health and the 
environment should then be assessed and, where 
appropriate, the requisite rehabilitation measures 
should be taken. 
6. Waste management 'from cradle to grave' 
Each of the three acknowledged main objectives of 
waste management policy can only be achieved by 
means of comprehensive management. This should 
be introduced as soon as possible and cover the 
entire 'lifetime' of the waste ('from cradle to grave'). 
This lifetime in many cases begins as early as the 
compilation of a product range and the design of 
the individual product, and may occur at a still 
earlier stage, e.g. with the introduction of a new line 
of production or the setting-up of a new production 
plant. In certain circumstances, even regional or 
structural policy decisions, on economic, energy or 
agricultural policy, for example, may be relevant to 
waste management, since they determine the future 
course of large-scale production of a particular type 
of waste in particular locations. 
7. Legislation 
7. 1. The failure of the Member States to incorpor­
ate individual waste management Directives into 
national law should be remedied as soon as possi­
ble. This is particularly important in the case of 
legislation to ensure the safe disposal of hazardous 
wastes, and the implementation of the Directive of 
20 March 1978 on toxic and dangerous waste. 
7.2. The four draft Directives on waste manage­
ment ('), and especially the draft Directive on the 
(') Proposal for a Directive on the dumping of waste at 
sea (COM(75) 688 final of 8 January 1975); 
Proposal for a Directive on containers of liquids for 
human consumption (OJ No C 204, 13. 8. 1981); 
Proposal for a Directive on the use of sewage sludge 
in agriculture (OJ No C 264, 8. 10. 1982); 
Proposal for a Directive on the supervision and con­
trol of the transfrontier shipment of hazardous wastes 
(OJ No C 53, 25. 2. 1983). 
6. 8. 84 Official Journal of the European Communities No C 206/65 
supervision and control of the transfrontier ship­
ment of hazardous wastes within the European 
Community and the draft Directive on the dumping 
of waste at sea (which dates back to 1976), should 
be adopted as soon as possible. The Economic and 
Social Committee has endorsed these Draft Direc­
tives and drawn attention to their urgency. 
7.3. The adoption of a draft Directive concerning 
the assessment of the environmental effects of cer­
tain public and private projects, also of long stand­
ing, should also prove very significant in achieving 
waste management objectives, since it provides that 
waste management considerations must also be 
taken into account before a decision is taken on 
such projects. An instrument of this kind is neces­
sary because the existing provisions on prior exami­
nation from the aspect of possible air or water pollu­
tion do not generally embrace waste management. 
7.4. In the Committee's view, there is probably no 
need to adopt further Directives for the time being, 
except to update existing Directives in the light of 
experience (e.g. Directive of 16 June 1975 on the 
disposal of waste oils) in order to facilitate or ensure 
their incorporation into national law, or to lay the 
requisite legal basis for any new waste management 
measures which may prove necessary in the future. 
It should be pointed out here that it may not be pos­
sible in future to retain the current practice of using 
mainly Directives to implement waste management 
policy, and only adopting directly applicable Regu­
lations in exceptional circumstances. It may be 
advisable henceforth, at least in certain areas, to 
make greater use of Regulations, which take effect 
without the need for legislation on the part of the 
Member States and therefore ensure that unified 
rules come into force at a given time in all Member 
States. Pending the results of a more detailed 
inquiry, let it merely be said for the present that the 
adoption of Regulations may possibly be preferable 
in the case of rules on the safe disposal of waste and 
certain measures limiting particular types of pack­
aging. 8. The role of research into waste 
8.1. The Community waste management pro­
gramme should be based on the most recent scien­
tific knowledge and special encouragement should 
be given to research in the following fields: 
— development of 'clean' technologies — manu­
facturing processes which generate little waste 
and use a minimum of energy but still yield 
goods of equal quality to those based on trad­
itional technologies, while the waste which is 
generated can be more readily re-used, 
— development of appropriate methods for 
upgrading agricultural waste and for recovering 
energy from household refuse, 
— development of techniques for monitoring 
closed-down tips and dumps, especially those 
used for special wastes, in order to detect poten­
tial pollution (delayed-action risks) and to ren­
der such tips harmless, 
— introduction of pilot projects on the recycling of 
plastics, 
— introduction, where appropriate, of pilot pro­
jects for management of all kinds of waste at 
local level, 
— introduction of 'clean' technologies in small 
and medium-sized undertakings also, 
— improved exchange of information on the 
results of research and experiments. 
8.2. In this context, the Commission should con­
tinue its current action on the recycling of municipal 
and industrial waste by launching a second research 
programme in this field. 
8.3. The results obtained in the research and 
development projects assisted by Community funds 
should be evaluated and notified to the Member 
States in a suitable form, so that they can be borne 
in mind when decisions are being taken on waste 
management measures. 
8.4. In giving further assistance to waste manage­
ment R&D projects, care should be taken to co­
ordinate the aid programme adequately with other 
Community aid measures. 
No C 206/66 Official Journal of the European Communities 6. 8. 84 
9. Heightening awareness of and improving inform­
ation on waste management issues 
9.1. The readiness of people to adapt their behav­
iour to waste management goals largely depends on 
the extent to which social 'environmental conscious­
ness' has developed. Even where this is generally 
well developed in individual persons or social 
groups, there is frequently a lack of awareness of the 
practical consequences for individual day-to-day 
behaviour. 
9.2. In the Committee's view, a Community waste 
management programme should therefore seek to 
fill this gap in public knowledge. One Member State 
has successfully introduced an 'environment mark', 
awarded by a panel of experts to good, long-lasting, 
safe and ecologically beneficial products (e.g. 
retreaded tyres, long-lasting silencers for motor vehi­
cles, recyclable paper, recyclable printed matter, 
reusable bottles, etc.). The Commission should look 
into the question of whether a 'European environ­
ment mark', to be awarded in the light of uniform 
criteria, should be introduced. 
9.3. The Committee also feels that the public 
should be better informed in order, inter alia, to 
increase acceptance of public authority waste-man­
agement measures and thus boost their effective­
ness. 
10. Creating appropriate 'background conditions' 
for the further development of waste manage­
ment 
10.1. Too little attention seems to have been given 
hitherto to the fact that the goal of maximum re­
cycling is not being achieved, partly because the 
necessary organizational and economic 'background 
conditions' are lacking. In the Committee's view, a 
European waste management programme should 
therefore put greater emphasis on creating such con­
ditions within the Community. The main condition 
is adequate market transparency as to the produc­
tion and types of waste and possibilities of recycling 
it, such as that which has been achieved to some 
extent in certain Member States through the creation 
of 'waste material exchanges' some time ago. 10.2. Ways should be examined of making use of 
the data available on waste management. A Com­
munity data bank system should be set up linking 
existing or yet-to-be-established national and/or 
technical data banks with a Community clearing 
office. The Commission's proposal for a data bank 
with a specialist data bank for toxic waste (EWA-
DAT) should be implemented quickly, as the lack of 
suitable information is creating a bottle-neck in the 
development of waste management. 
10.3. Suitable conditions for the further develop­
ment of waste management could, in the opinion of 
the Committee be provided by measures such as: 
— the installation of containers for the separate 
collection of waste such as paper, glass, etc., in 
appropriate and generally accessible sites, 
— measures to encourage the separation of waste 
'at source', e.g. in the home, 
— conclusion of long-term collection and delivery 
contracts for recyclable waste, 
— continuation and adaptation to the new con­
straints of raw materials conservation and 
environmental protection of the conventional 
structures for collecting and recycling waste 
paper, glass, metal, etc., 
— stepping up waste recycling by means of closer 
cooperation between local authorities and 
undertakings in the waste sector, 
— the encouragement of inter-regional facilities for 
waste recycling or disposal, where the requisite 
infrastructures are not available at local level 
and cannot be provided, 
— closer cooperation at Community level to set up 
inter-sectoral recycling in industry, and overall 
management of particular types of waste, e.g. 
tyres, 
— collection of unused medicines by pharmacies. 
11. Cooperation between the State, economic 
operators and interest groups 
11.1. Cooperation between government depart­
ments responsible for environment policy on the 
one hand, and agriculture, industry, consumers' 
6.8.84 Official Journal of the European Communities No C 206/67 
organizations and other associations on the other, 
should in the Committee's view be extended and 
strengthened as far as possible in the context of a 
European waste management programme. 
11.2. The Committee feels that this type of cooper­
ation is, in certain cases, the most appropriate 
instrument for achieving waste-management objec­
tives. The cooperation principle runs into difficul­
ties where the partners at a public authority level are 
not sufficiently willing to cooperate or where agree­
ments are not observed. Legal or administrative act­
ion by the State will be necessary in such cases in 
the future also. 
11.3. Cooperation with trade and industry could, 
for example, take the form of agreements designed 
to reduce the proportion of packaging material in 
total waste, and especially to stabilize the use of 
returnable containers. Agreements could also be 
reached on the elimination of heavy metals from 
household waste, the reduction of toxic sludge from 
the surface treatment of metals, introduction of 
compulsory collection by retailers of used batteries, 
left-over drugs, large household appliances, etc., 
and increased recycling of waste paper. 
11.4. To avoid distortion of international compe­
tition, however, the agreements concluded under 
such cooperation should be similar in each Member 
State and their validity recognized in the Community 
and its neighbours. 
11.5. In practical terms, the agreements should 
lead to closer involvement of social action groups 
(consumer associations, consumer information off­
ices, product testing institutes, etc.) in the dissemi­
nation of information on the subject of waste. 
11.6. An attempt should also be made to harness, 
as it were, the natural interest of local and regional 
bodies (e.g. local administrations or interest groups 
of various kinds) in improving environmental con­
ditions in their area, in order to achieve waste man­
agement goals. 12. Waste management as a component of an overall 
policy 
12.1. One of the aims of a Community waste man­
agement policy should be to integrate waste man­
agement aspects from the outset in programmes for 
government action in fields relevant to waste man­
agement (transport infrastructure programmes, land 
use schemes, development plans for the economy, 
agriculture, energy supply, etc.). 
12.2. To this end, ways and means must be found 
to ensure that when government programmes, laws, 
decrees and other provisions are drawn up, public 
works projects planned, etc., a comprehensive 
assessment of their compatibility with the environ­
ment, including waste management aspects, is made 
at an early stage. It appears to the Committee that a 
useful starting-point for the exercise of such influ­
ence would be the decisions on the granting of 
Community aid to Member States for national 
public works projects. The granting of such aid 
should in future be made conditional in every case 
on the results of an evaluation of compatibility with 
the environment, including compatibility with waste 
management objectives. 
13. Supervision 
13.1. The Committee stresses that the success of 
waste management measures taken by the Member 
States and the Community is largely contingent on 
the operation of suitable official monitoring insti­
tutions by the Member States and the carrying out 
of adequate checks by these bodies. 
13.2. Some Member States have already been 
experimenting for some time with particular types of 
public supervisory bodies. For example, in one 
Member State there are special public authorities 
with the task of monitoring compliance with the 
provisions on compatibility with the environment. 
In another, the public bodies responsible for moni­
toring enjoy a good deal of independence from the 
political authorities. The Committee feels that per­
sons responsible for implementing legislation and 
monitoring its observance should be guaranteed 
freedom of action to shield them from pressure from 
conflicting interests and to ensure that they are free 
to take the requisite waste-management measures to 
protect human health and the environment. 
No C 206/68 Official Journal of the European Communities 6. 8. 84 
The Committee recommends the Commission to 
evaluate the track record of these institutions in the 
individual Member States and to submit a report, if 
necessary accompanied by appropriate proposals. 
13.3. The Commission should also examine the 
extent to which voluntary control by private and 
public sector companies has proved its worth; this 
has for some time taken the form in one Member 
State of so-called 'waste managers'. 
'Waste managers' are responsible for ensuring that 
legal and other provisions concerning waste man­
agement are observed. They also advise or provide 
information to the management and staff and make 
practical suggestions not only regarding the appro­
priate waste management measures to be taken but 
also on the introduction at the product design stage 
of corresponding processes. 
14. Selection of sites 
Waste-management measures may themselves prod­
uce pollution in other ways. The storage of waste in 
dumps may, for example, pollute the soil, ground 
water or the atmosphere, thereby jeopardizing the 
protection of nature and the conservation of the 
countryside. The incineration of waste inevitably 
releases substances into the air, some of which are 
harmful. And there are other similar cases. A Euro­
pean waste management programme should ensure 
that a comprehensive study of environmental effects 
is carried out at an early stage in the selection of 
sites for waste treatment plants and that, if neces­
sary, the plans are modified accordingly. 
15. Worker protection 
The Committee also emphasizes that the labour pro­
tection aspects of waste management measures must 
Done at Brussels, 24 May 1984. be given appropriate attention. This applies in parti­
cular to persons engaged in the disposal of highly 
dangerous waste at special refuse dumps, inciner­
ation plants or other types of plants. People with 
duties in the area of waste management must not 
suffer any damage to their health as a result. When 
an EC waste-management programme is being 
drawn up, the worker-protection provisions should 
therefore be reviewed to determine the extent to 
which they provide the abovementioned persons 
with adequate health protection and whether or not 
additional harmonized rules are required. 
16. European waste statistics, etc. 
16.1. It is imperative to introduce as soon as poss­
ible standardized statistics on waste in the Com­
munity based on uniform concepts and data compi­
lation methods, and relating to the generation, util­
ization and disposal of hazardous wastes. 
16.2. Regular reports should be issued on the state 
of waste management within the Community, on the 
basis of data available at Community level. These 
reports should include lists of available primary and 
secondary raw materials; they could also cover 
plans to reduce the production of particular types of 
waste, to develop longer-lasting products, and to 
reclaim raw materials from waste. 
16.3. The Committee takes the view that, to ensure 
the success of such a programme, the Commission 
must set up an appropriate and effective administra­
tive structure in the form of a separate administra­
tive unit for waste management, similar to that 
which exists for water management, and must pro­
vide it with the necessary funds and staff. 
The Chairman 
of the Economic and Social Committee 
Francois CEYRAC