Scope of data collection on waste treatment operations in Member Countries Summary of responses to the questionnaire

Transcription

1 European Commission EUROSTAT WASTE/TF/42/05(2004) Original in EN Point 5 of the agenda Scope of data collection on waste treatment operations in Member Countries Summary of responses to the questionnaire ARGUS GmbH for Eurostat Meeting of the Task Force on Quality issues and Preliminary results of the pilot studies on waste statistics (Nace A and B) Meeting of 5 and 6 July July Bech Building Room A4/45 6 July Bech Building Room B3/404

2 Scope of data collection on waste treatment in Member Countries page 1 Contents 1 Introduction Scope of the WStatR with regard to waste treatment Objective of the questionnaire Responses to questionnaire Registers and data sources Waste treatment activities not covered by data collection Reporting exemptions for small facilities Reporting exemptions for specific treatment operations Recycling at the site of waste generation Understanding of internal recycling Understanding of site of waste generation Exemption of internal recycling from data collection and permitting Discussion and conclusions... 10

3 Scope of data collection on waste treatment in Member Countries page 2 1 Introduction This paper summarises information on the scope of waste treatment statistics in Member Countries. The presented information was submitted by the Member Countries in response to the questionnaire sent by Eurostat mid of May. 1.1 Scope of the WStatR with regard to waste treatment The scope of the WStatR for the production of statistics on waste treatment is defined in Section 1 of Annex II WStatR. Statistics have to be compiled for all waste recovery and disposal facilities that run any of the waste treatment operations referred to in Section 8(2) of Annex II. Excluded from the scope of Annex II are: facilities whose waste treatment activities are limited to the recycling of waste on the site where the waste was generated (Annex II, section 1, subsection 2), and waste treatment activities that are purely non-economic activities. For the definition of the term recovery and disposal facility the WStatR refers to the Waste Framework Directive (75/442/EC). Article 2(f) WStatR stipulates that:... recovery or disposal facility shall mean a facility that requires a permit or registration pursuant to Articles 9, 10 or 11 of Directive 75/442/EC (Article 2(f) WStatR) The Articles 9 and 10 of the Waste Framework Directive (WFD) establish a general obligation to obtain a permit for all establishments or undertakings which carry out one of the operations specified in Annex IIA and Annex IIB of the WFD. Under certain conditions, Article 11 WFD allows the Member States to exempt specific treatment operations/facilities from the permitting obligation, but requires that these operations have to be registered with the competent authority. Accordingly, treatment activities that are exempt from the obligation to obtain a permit and which only have to register with the competent authorities are not necessarily outside the scope of the WStatR. Exemptions from the duty to be registered, e.g. for small scale facilities, are not explicitly foreseen in the WFD. 1.2 Objective of the questionnaire For the production of comparable statistics it is crucial that the scope of the reporting obligations as stipulated in the WStatR is understood and applied in the same way in all Me mber States. The questionnaire was designed to provide information on the scope of waste treatment statistics in Member Countries in order to identify major differences between Countries and in relation to the WStatR, and to identify needs for further harmonisation The questionnaire focussed on the following questions: 1. Which data sources are used by Member Countries? 2. Which waste treatment activities are exempt from the obligation to get a permit? 3. Which waste treatment activities are not covered by data collection? 4. How do Member Countries deal with the question of recycling of waste at the place of generation. The paper includes the to the questions 1, 3 and 4.

4 Scope of data collection on waste treatment in Member Countries page 3 2 Responses to questionnaire The questionnaires were sent on 14 May to the 27 Member Countries listed in Table 1. So far, 13 Countries have answered. Table 1: Overview of Countries that responded to the questionnaire (dated 30/06/2004) Date of No. Country & Institution Contact person & institution reception 1 AT Austria Elisabeth Schachermayer, UBA BE Belgium 3 CY Cyprus 4 CZ Czech Republic Alena Prazakova, CZSO DE Germany Sarah Nasse, DESTATIS DK Denmark 7 EE Estonia 8 GR Greece 9 ES Spain 10 FI Finland 11 FR France Thierry de Corlieu IFEN HU Hungary 13 IR Ireland Caitriona Collins, EPA IS Island 15 IT Italy Mara Cammarrota, ISTAT LT Lithuania Danguole Krepstuliene, Statistical Office LU Luxembourg Serge Less, Environment Administration LV Latvia 19 MT Malta Said George, Statistical Office NL The Netherlands 21 NO Norway Oystein Skullerud, SSB PL Poland Wieslawa Domanska, CSO PT Portugal 24 SE Sweden Jan Grünberger, SCB SI Slovenia Mojca Zitnik, Statistical Office SK Slovakia 27 TR Turkey 28 UK United Kingdom 3 Registers and data sources Question 1 asked for the registers and data sources that are used in Member Countries for the compilation of waste treatment statistics. The question was: Which registers and/or data sources are used for waste treatment statistics? Administrative registers Registers or data from industrial associations Consignment notes Statistical Business Register

5 Scope of data collection on waste treatment in Member Countries page 4 The questionnaire asked to specify the different sources (in particular the administrative registers) and the purpose of their use.the answers can be summarised as follows: In general, data on waste treatment are based on administrative registers: All Countries except the Czech Republic report that they use administrative sources for waste treatment statistics. Some Countries rely exclusively on administrative registers (IT, LT, LU, PL, SI), others use additional data sources (AT, DE, FR, IR, NO, SE). The Czech Republic is the only Country that relies exclusively on the Statistical Business Register for the selection of reporting units. Four Countries (AT, DE, FR, IR) use consignment notes for statistical purposes. Austria and Germany use them for control and information of hazardous waste management within the country. France and Ireland use them for data on transboundary shipment of hazardous waste only. Data from associations are used by Norway and Sweden in addition to administrative data sources: Norway uses data on paper and board recycling from the Norwegian paper industry; Sweden uses the Register from the Swedish Association of Waste Management, an association that includes mainly municipalities, for information on landfills, incineration plants and biological treatment plants. Whereas some Countries have established central registers on national level others have to rely on different databases. In some Countries registers are implemented on different administrative levels reflecting the responsibility for the permitting of the treatment facilities. Italy and Ireland for example have established separate registers for treatment facilities that need a permit in accordance with Art 9 and 10 WFD, and those facilities that are exempt from permitting but have to register with the competent authority. Table 2: Data sources for waste treatment statistics Administrative registers Data from associations Consignment notes Statistical Business Register AT CZ DE FR 4) IR 5) IT LT LU MT NO 2) PL 1) SE 3) SI 1) A new information system based on administrative data is under development. 2) Data on paper and board recycling from the Norwegian paper industry. 3) Register from Swedish Association of Waste Management (Members are mainly municipalities) which contains data on landfills, incineration plants, and biological treatment plants 4) Use for statistics about import or export of waste 5) Transfrontier shipment of waste data used to compile information on waste exported.

6 Scope of data collection on waste treatment in Member Countries page 5 4 Waste treatment activities not covered by data collection Section 3 of the questionnaire addresses the coverage of data collection on waste treatment. The question was: Which waste treatment operations/facilities are excluded from data collection on waste treatment in your country at present? The Countries were asked to list the waste treatment facilities / waste treatment operations that are not subject to reporting obligations and are not addressed by statistical surveys, e.g. on account of their size, the type of operation or for other reasons. Some specific treatment operations that should be considered when answering the question were pre-defined in the annex to the questionnaire. The Countries were also asked to specify threshold where applicable. The answers are described verbally in the following sections 4.1 and 4.2. In addition, an overview of the answers is shown in Table 3. Table 3 distinguishes between: operations that are generally exempt from data collection, regardless of the treated quantities (marked with ), and operations that are exempt from data collection in connection with a threshold, thus excluding small treatment facilities or the treatment of low quantities from data collection (marked with T). 4.1 Reporting exemptions for small facilities Astonishingly few Countries indicate that they have officially exempted small waste treatment facilities from data collection: A general exemption from reporting, regardless of the type of treatment operation, is reported only by Lithuania. In Lithuania, all enterprises treating less than 1 ton/month of non-hazardous or 50 kg/month of hazardous waste are not addressed by statistical surveys Quantitative thresholds for specific waste treatment operations are established in Austria, Luxembourg, and Slovenia. Slovenia has set a threshold of 5 kg/year of treated hazardous waste or 10 tonnes/year of treated non-hazardous waste. The Czech Republic selects reporting units on the basis of the Statistical Business Register and has established a threshold based on the number of employees. Companies belonging to NACE groups 37 and 5157 with less than 5 employees are not addressed by surveys. The other Countries do not report official exemptions for small treatment facilities. 4.2 Reporting exemptions for specific treatment operations The following table describes the reporting exemptions for specific treatment operations that are established in Member Countries. Treatment operations Incineration and coincineration of waste Exemptions from reporting in Member States Slovenia is the only country that reports a general reporting exemption for small facilities that incinerate or co-incinerate waste. Official reporting exemptions for the incineration of vegetable waste are established in Luxembourg and Poland for: - the burning of vegetable waste in order to avoid pest infestations (LU); - the burning of vegetable waste outside of installations (PL).

7 Scope of data collection on waste treatment in Member Countries page 6 Composting and fermentation plants Soil treatment Deposit of dredging sludge Reprocessing and reuse of waste from road works Spreading of waste on land for agricultural purposes or ecological improvement Deposit, storage and backfilling of waste from mining and quarrying at the site of excavation Temporary treatment activities (e.g. treatment of C&D waste by mobile plants) Slovenia and Luxembourg have exempted small composting plants from reporting. No exemptions were reported for fermentation plants. Norway reports that soil treatment is generally excluded from data collection. Slovenia has exempt from reporting the treatment of small amounts. Luxembourg has established an exemption for the deposit of small amounts of soil. Several Countries exclude the deposit of dredging sludge from data collection: General exemptions are reported by Norway and Luxembourg. Austria and Slovenia have established exemptions combined with thresholds. In Poland the exemption is valid only for non-contaminated material under specific conditions that are stipulated in the Waste Act. The reuse of inert waste from road works at the place of generation is generally exempt from reporting in Norway. In Luxembourg an exemption is valid only when the waste is reused without prior treatment. In Luxembourg the spreading on land of sewage sludge, manure and marc is exempt from the obligation to obtain a permit and from data collection. Slovenia collects data above the established threshold. All other Countries do not indicate that the spreading of waste on land is excluded from data collection. Official exemptions for the deposit of mining waste at the site of generation are established in Luxembourg, Norway and Poland. In Poland, the exemption applies only under specific conditions that are stipulated in the Waste Act. Slovenia is the only country that reports exemption from reporting of temporary activities for small facilities. In addition to the treatment operations described above some Countries named additional operations that are exempt from data collection: Some entries refer to waste from agriculture, fishery and forestry. This issue is discussed in detail in the reports from the pilot studies. Some entries refer to the temporary storage, the pre-treatment and sorting of waste which is excluded from reporting in some Countries. This issue will also be subject to pilot studies. Other reporting exemptions refer to the transfer of waste for reuse for non-economic purposes and to non-economic treatment activities like backyard composting.

8 Scope of data collection on waste treatment in Member Countries page 7 Table 3: Waste treatment activities that are exempt from data collection Treatment operations predefined in the questionnaire AT CZ 1) DE FR IR IT LT 2) LU MT NO PL SE SI 3) Incineration/co-incineration in small incineration plants Incineration of untreated vegetable waste (e.g. wood, straw,...) T T Composting plants T T Fermentation plants for organic waste, manure, etc. Soil treatment plants (biological, mechanical, ) T Remediation of contaminated sites in-site or on-site T Deposit of dredging sludge beside waterways or elsewhere T T Spreading on land of waste for agricultural purposes or ecological improvement Use of waste for land reclamation Reprocessing and reuse of waste from road works at the place of generation Discharge, storage and backfilling of waste from mining and quarrying at the site of excavation Temporary treatment activities (e.g. treatment of C&D waste at construction sites by mobile plants) Treatment operations added by member countries T T T Deposit of soil Manufacturing industries using secondary raw materials from the own production Recovery of blood of animal or poultry origin T Sorting and pre-treatment of waste Temporary storage of waste T ELV collection sites Use of harvesting residues and/or manure for agricultural purposes on-site Recovery of faecal matter of animal or poultry origin in the form of manure or slurry Timber logging residues left in the forest Fish gutting dumped in the ocean Backyard composting Transfer for re-use to natural persons or organsiations for non-economic activities 1) NACE 37 and 5157 facilities with less than 5 employees are not addressed by the statistical survey 2) Enterprises treating <1 ton/month of non-hazardous or <50 kg/month of hazardous waste are not addressed by statistical surveys. 3) For all operations marked with T Slovenia has set a threshold of 5 kg/year of treated hazardous waste or 10 tonnes/year of treated non-hazardous waste Explanation: Operation is generally exempt from data collection; no threshold T Operation is exempt from data collection if falling below threshold

9 Scope of data collection on waste treatment in Member Countries page 8 5 Recycling at the site of waste generation Section 4 of the questionnaire addresses the question how Member Countries deal with the issue of recycling of waste at the site of generation in their national waste treatment statistics. The questions were: 4a) Which waste treatment activities are considered to be internal recycling processes? 4b) How is the term site of waste generation understood and applied? Does their exist a legal definition? 4c) Is recycling at the site of waste generation exempt from permitting and/or reporting? 5.1 Understanding of internal recycling The answers to question 4a are shown in Table 4. The comments show that the understanding of the term recycling at the place of waste generation is extremely different in the Countries. The following interpretations can be distinguished: Some Countries point out that it is not possible to clearly assign specific treatment activities to the term recycling (AT, SE). The Czech Republic classifies recycling as treatment activities according to the operations R4 and R5 that lead to the reintroduction of the waste into the production process. Some Countries use the term internal recycling in a much broader sense including basically all types of recovery operations that take place at the site of waste generation. Table 4: Understanding of internal recycling in Member Countries Country Answers of Member Countries AT CZ IR LU NO SE No special waste treatment activities are allocated to the definition of recycling Treatment activities according to the recovery operations R4 (Recycling/reclamation of metals and metal compounds) and R5 (Recycling/reclamation of other inorganic materials), under the condition that: a) the enterprise has a internal facility for waste recycling, and b) the waste is returned back to the production process as a raw material. In both cases the waste does not go out of the enterprise. All those waste recovery operations that are technically associated with an IPPC authorised activity. Stats from these operations are reported as part of the Annual Environmental Report for each site. In 2001, the following R codes were reported to EPA in the industrial waste dataset as having been managed onsite of generation: R1, R2, R3, R4, R5, R7, R9, R10, R11, R12, R13 Recycling of production waste e.g. ferrous and non ferrous metals, plastic waste, wood waste; Recycling of organic waste on farms (manure, straw...); Recycling of demolition and construction waste without treatment for refilling and for remodelling the landscape; Discharge, storage and backfilling of waste from mining and quarrying at the site of excavation. Resmelting of metals or glass etc. on-site; Recycling of plastics/paper/pulp/concrete etc. on-site; Backyard composting; Use of harvesting residues and/or manure for agricultural purposes on-site; Timber logging residues left in the forest; Fish gutting dumped in the ocean. There are no general criteria specifying such activities

10 Scope of data collection on waste treatment in Member Countries page 9 SI Incineration or co-incineration of waste; Composting of waste; Spreading on land of waste for agricultural purposes or ecological improvement; Solvent reclamation; Recycling of metal and metal compounds; Recycling of other inorganic materials; Oil refining or other reuses of oil. 5.2 Understanding of site of waste generation All nine Countries that answered this question stated that there exists no legal definition for the term site of waste generation in their country. Some Countries gave explanations how they usually apply this term in practice. Basically, three types of understanding can be distinguished: the local definition that focuses on the spatial dimension of a company or facility, the legal definition that focuses on the legal entity of a company; the technical definition that is based on activities that are technically associated. Aspects of all three approaches can be found in the answers of the Member Countries shown in Table 5. Norway for example focuses on the local unit, but extends the local definition to the ecosystem in case of forestry and fishery. Slovenia understands the site as business entity, thus emphasising the legal aspect. Ireland chooses a more technical approach and refers to the definition of installation in the IPPC Directive that embraces those activities that are technically associated. Table 5: Application of the term site of waste generation in Member Countries Country Answers of Member Countries IR LU NO PL SI We consider 'site' to embrace those activities that are technically associated; very similar to the interpretation of Installation in the IPPC Directive. We also rely on the understanding of the Planning Authorities in relation to their interpretation of the development site. In certain circumstances this can mean that different parts of the site may be geographically separated. The legal unit of a company has to be considered (e.g. farm with livestock breeding and crop production is one unit (site)). Company A in Luxembourg and Company A in Bettembourg are two different units. Company A may consist of a metal scrap storage place, blast furnace, continuous casting, mill train and a landfill for slags These different components have to be considered as a site (unit). At the site of generation means at the same local unit; but in the case of forestry and fishery waste, in the same ecosystem. The term site of waste generation is understood and applied like place installation, facilities or other place where waste producer produces waste. The site means a business entity which recovers or reuses its own waste

11 Scope of data collection on waste treatment in Member Countries page Exemption of internal recycling from data collection and permitting Most Countries state in the questionnaire that they make no difference between internal and external recycling. In those Countries internal recycling in is neither exempt from the obligation to obtain a permit nor from data collection. Norway and Germany indicate that the internal recycling of waste is excluded from data collection and from the obligation to get a permit. In Luxembourg, internal recycling processes may be exempt from permitting on request in accordance with the waste management law. Luxembourg points out that it is not always clear if the figures from treatment facilities include internally recycled quantities as some companies indicate these quantities in their annual reports and while others don t. Some Countries did not answer the question, e.g. because there exist is no definition for recycling. The Czech Republic describes that data on internal recycling are collected but are excluded form the statistics after checking and processing of data. Other Countries did not describe how they proceed with data on internal recycling in the course of data processing. It is not clear from the questionnaires if the internally recycled quantities are included in the total recycling figures or if they are displayed separately in the statistics. 6 Discussion and conclusions To get an idea of the scope of data collection in Member Countries the Countries were asked for information on the scope of waste treatment statistics. The questionnaires focused in particular on the exemptions from data collection that are established in Member Countries. Although the obtained information does not provide a complete picture of the answers clearly indicate some areas where further harmonisation is needed. So far, the scope of data collection on waste treatment in Member Countries is far from being congruent. Countries apply different criteria to exclude specific treatment operations from data collection. Whereas some Countries exclude specific treatment operations in general, others exclude them under specific circumstances. Considerable differences obviously exist with regard to data collection on some big waste flows like mining waste, C&D waste, waste from road construction, dredging sludge, waste from agriculture and forestry, and contaminated soil: Different approaches are chosen with regard to waste that is reused at the site of generation, with or without prior treatment. This applies for example to mining waste, waste from road construction, C&D waste, and to agricultural waste. Here, a harmonisation of national approaches is urgently needed. In general, a grey area exists where the final destination of waste is not a treatment facility but agricultural and non-agricultural land, road construction, or other construction purposes. Whereas EU legislation clearly requires to collect data on the agricultural application of sewage sludge such clear regulations do not exist for other types of waste used in agriculture (mineral wastes, compost, remains from fermentation plants, etc.) or are disposed of on land (dredging sludge). This question should be included into the scope of the pilot projects on agriculture, forestry and fishery.

12 Scope of data collection on waste treatment in Member Countries page 11 Recycling at the site of waste generation Harmonisation is necessary with regard to the recycling of waste at the site of generation. Countries obviously deal very differently with internal recycling and recovery processes. The WStatR excludes internally recycled waste from the reporting obligations on waste treatment. This means that the WStatR considers the site of waste generation as a block box with regard to recycling processes (but not with regard to other recovery operations). The rationale behind this approach is that material flows within production processes are often rather complex. The classification of material flows into products and waste can be very difficult because recycling often is an integral part of the production. As a consequence, such data are hard to collect in a standardised and comparable way. In order to achieve comparable results and to avoid data gaps it is necessary to clearly define the boundaries of this black box, and to keep the black box as small as possible. There must be a common understanding of what is meant by the terms recycling and site of waste generation. Both terms should be defined in a rather narrow way. Based on these considerations we make the following proposal: The term recycling at the site of waste generation shall be limited to the use of waste as secondary raw material in production processes. This interpretation would be line with the recycling definitions as established in product-related EU-Directives (WEEE- and ELV- Directive). There it is stipulated that: recycling means the reprocessing in a production process of the waste materials for the original purpose or for other purposes, but excluding energy recovery ( ) With regard to the site of generation this means that the site has to be defined on the basis of technically associated installations of a company. Such a definition could prevent that the use of production waste for purposes that are not directly associated with the production (e.g. use of mineral production waste for construction purposes on the company s premises) would be classified as internal recycling. A purely local or legal site definition would not be sufficient for this purpose. It has to be checked if the definition of installations in the IPPC-Directive could helpful for the purposes of the waste treatment statistics. The term recycling at the site of waste generation should not generally be extended to activities in the mining sector, the construction sector or to agriculture, forestry and fishery as practised by some Countries. Such a broad interpretation would result in too much latitude for interpretation and a very vague definition of the scope of waste treatment statistics.