Space industry position regarding Article 9 of the revised Waste Framework Directive 2008/98/EC

Eurospace is calling on EU Member States to consider non-waste status of space products at the end of their service life for transposition of the EU’s revised Waste Framework Directive

Eurospace announces the release of the SPACE INDUSTRY POSITION REGARDING ARTICLE 9 OF THE REVISED WASTE FRAMEWORK DIRECTIVE 2008/98/EC (WFD). The position paper has been prepared in the frame of the WFD Task Force.

According to the position the notification duty under Article 9 (1) (i) of the revised Waste Framework Directive 2008/98/EC does not apply to equipment designed to be sent into space and related means of transport (launch vehicles and spacecraft, such as satellites for telecommunication, navigation or space exploration) which do not result in “waste” on the EU territory. Such products – not being part of the Circular Economy – are considered to fall outside the scope of the Directive.

The European Commission interpretation obtained by Eurospace insists on the applicability of Article 9 of the WFD to space products, arguing that an explicit exemption is not foreseen in the Directive. With this interpretation the implementation of Article 9 does not seem to promote any added value for the Union, its citizens and workers, nor for the environment. But it will clearly increase the financial and administrative burden for the industrial sector, as well as for ECHA and the relevant national authorities. Furthermore, the obligations for information disclosure may potentially conflict with other requirements applicable to the space sector, as further detailed in the position paper.

Eurospace is therefore now reaching out to EU Member States with its position, requesting them to take it into account when transposing the Directive into national laws (which is required by 5 July 2020), and inform their approach taken to Eurospace for due action by the European space industry.


  • Eurospace position paper
  • Annex 1 – EC reply to Eurospace of June 14th 2019
  • Annex 2 – Eurospace response to EC of August 8th 2019
  • Annex 3 – COM Non-paperWFD of June 20th 2019


Related information:


  • Contact: Pierre Lionnet, Secretary General and Director of Research, ASD-EUROSPACE, +33-(0)1 44 42 00 70