BACI’s statement to The Ministry of Councils and MOEW on a possible ban on transboundary shipment of RDF from EU Members

The cement industry in Bulgaria has been using waste as an alternative fuel (AF) since 2002. Co-processing of alternative fuels in general and of refuse-derived fuel (RDF) are good examples of circular economy since they can reduce CO2 emissions and landfilling to the benefit of the society. All cement plants have IPPC permits and have invested hundreds of millions of euro for the necessary environmental investments to co-process AF in a sustainable way. The cement producers have established a network of Bulgarian waste management companies, which collect wastes from various Bulgarian waste generators, process them and supply the alternative fuels to the cement plants. In parallel to this process, the cement companies have been performing transboundary shipments of certain quantities of wastes, incl. RDF since 2008, fully in compliance with EU Regulation (EC) No.: 1013/2006 and the effective national legislation in the area of waste management.

The transboundary shipments have been necessitated by the insufficient quantity of RDF produced by the waste-separation installations in Bulgaria, which comply with the quality requirements for the production of cement. RDF with inconsistent quality interferes with the combustion process in the cement kiln whereas high-quality RDF allows us to take on more local wastes, even with poor quality, for recovery through incineration.

The cement industry in Bulgaria gives priority to RDF and waste of local origin whereby more than 50% of the non-hazardous waste used in the clinker kilns originates from Bulgaria. Aa far as concern the local high-quality production of RDF we will appreciate the Government and competent authorities support to develop modern installations to produce RDF from municipal and/or industrial wastes following the best practices of Varna, Haskovo and Sofia Municipalities. The necessary investment can be performed through EU funding programs.

In addition, no breaches have been established of the permits issued for activities involving waste, the integrated permits and the permits for transboundary shipment of waste during the numerous inspections and checks performed by various institutions throughout the years.

“The Bulgarian association of cement industry” is against the discussed ban on transboundary shipment of RDF from EU Member States. We believe, that to prevent potential infringements, the exercise of specialized powers and control by the competent authorities under the current legal framework would be more productive than imposing a complete ban.

Such a ban – if imposed- contravenes the EU regulations, runs counter to the principles of the circular economy and will reduce the competitiveness of the Bulgarian cement industry. In addition, we find such a measure to contradict with the targets set in the Green Deal adopted by the European Commission and the overall pursuit of climate neutrality. It is precisely the promotion of use of resources part of a clean circular economy that is brought as the way for reducing carbon emissions and achieving sustainable development which is environmentally friendly.