Exponential growth of an invisible pollutant
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1 Circular Economy Interface between waste and chemicals legislation a recyclers perspective Foto: Peter Essick Chris Slijkhuis Müller Guttenbrunn Group Austria recycling.com Exponential growth of an invisible pollutant June 2018: 410,79 ppm CO 2 Emitting CO 2 is free of charge It is a most urgent global environmental threat And..this discussion decoupled from debates over toxics and SVHC s 1
2 The car parts/car can be identified in a database....for a new car or for a car in use. Source Hyundai 3 These car parts/car cannot be identified anymore... Source: MGG as Car Recycler once these cars have reached their End Of Life 4 2
3 Why micro management on parts level is impossible for us Cars have some parts We treat cars at this location This is some 300 Mio car parts/year Goods movements/year (Rail and trucks) We are supplied by sources all different In total 120 European Waste Codes Micro Management on parts level is not possible... 5 The WEEE Recycling Process TAC Guidance Substances, preparations and components may be removed manually, mechanically or chemically, metallurgically with the result that hazardous substances, preparations, and components and those mentioned in Annex II are contained as an identifiable stream or identifiable part of a stream at the end of the treatment process. A substance, preparation or component is identifiable if it can be (is) monitored to prove environmentally safe treatment. May I invite you to have a look at our WEEE Recycling Process? 3
4 May I invite you to our world of WEEE recycling... De Pollution Batteries, Capacitors etc. 7 De Pollution with Smasher 2.0 MGG Patented Smasher Taking out Hazardous components, such as Capacitors > 25mm Batteries Toner Cartridges Valuable components, such as Printed Circuit Boards Spools E Motors Fractions disturbing further separations, such as Wood or other fibres 4
5 WEEE recycling shredding and ferrous metal recovery De Pollution Shredding Batteries, Capacitors etc. Ferrous Metals 9 EVA Shredder, specialized for WEEE Shredding Extremely efficient air treatment and fire fighting techniques Very low noise shredding Separation of Ferrous Metals Shredder residues Heavies Lights Dust fraction Clean air (approx. 2 mg/m3 dust) 5
6 WEEE recycling non ferrous metal recovery De Pollution Shredding Post Shredder Treatment Batteries, Capacitors etc. Ferrous Metals Non Ferrous & Precious Metals 11 Treatment of WEEE Shredder Residues Post Shredder Technologies The dry and wet separation techniques consist of: Size (sieving) Density separations Induction Colour & other sensor based Surface to weight ratio s etc. Resulting in concentrates of Non Ferrous Metals (Copper, Aluminium, Brass, Stainless etc.) Printed circuit boards Plastics 6
7 WEEE recycling PCR plastics recycling De Pollution Shredding Post Shredder Treatment Plastic Recycling Batteries, Capacitors etc. Ferrous Metals Non Ferrous & Precious Metals Polymer pellets end of waste 13 MGG Polymers WEEE Plastics Recycling Goods In and Pre processing Each receipt is assayed Material cleaned from non plastics High tech plastic separation Cleaning and separarions PP, HIPS, ABS and PC ABS Blending, Extrusion and Compounding Lab Analyses RoHS Physical, Chemical & Rheologic parameters Output Material some MT of PCR plastics drop in replacing virgin 7
8 The alternative is sending the WEEE away from Europe. The western Africa route The China route A closer look at this alternative 15 Supply Chain in China the trade with plastics 8
9 Recycling in China...sorting often manual work Recycling in China manual sorting & Sink/Float 9
10 Recycling in China blending and extrusion Question: What happens with non recycled materials? 10
11 MGG s sustainable model to re produce plastics from WEEE Procurement Processing Selling Growing supply Land filled/incinerated Mechanical mining process Innovative technologies Green products Virgin like quality possible Self replenishing Sustainable Growing supply < 10% of energy < 10% of water consumption Save about 3 4 tons CO2/ton More sustainable business PCR plastics Non target material is incinerated Legislation overview Brominated Flame Retardants EEE Products IT electronics (microprocessors, computer servers, modems, printers, copy machines ) Consumer electronics (hair dryers, heaters, TV sets, laptops ) White goods (tumble dryers, dishwashers, washing machines ) Plastic Parts Housing Printed circuit boards Cables Connectors HBCD DecaBDE 3 c PentaBDE c OctaBDE BDP RDP TBBPA DOPO EBP ATH MDH ATO Br d PS Mel.Cyanurate Regulations Annex XIV POP under Stockholm Restriction under RoHS Restriction under REACH No restriction Source: EFRA 22 11
12 Restricted BFRs in WEEE today and adding Dea BDE Restricted today Added restriction Deca BDE The current Deca BDE discussion might end WEEE plastic recycling.. Why can t we live with a UTC threshold of 10 ppm for Deca BDE? Complex analyses by Gas Chromatography cannot be used for recycling Continuous analyses are required per batch of 1000 kg Preparation of samples is too complex and samples must be small The time required for one analysis is too big The costs are prohibitive higher than the value of the recyclates. X ray fluorescence spectrometry (XRF Analysis) XRF analysis has proven to be the only viable method for recycling processes in practice There is a standard for this EN :2014 It screens not only BFR s but also other RoHS substances material XRF measures total bromine Making the analysis impossible for extremely low concentrations. XRF method is validated for 1000 ppm Lower values (<1000 ppm) for UTC and LPC would have serious repercussions Deca BDE in larger batches represent 22 % of BFR s All restricted BFR s in E Waste have 1000 ppm threshold One different value for deca BDE would complicate QM procedures a lot We fail to see why deca BDE would be treated differently then other PBDE s Deca BDE was listed in the EU Chemical Legislation (REACH) only last year The WEEE recycling industry needs an UTC threshold of 1000 ppm for deca BDE 12
13 This is how it feels.. Recycler This is how we believe it should be Conformity to Standards Downstream controls Legal compliance Ressource savings Energy savings CO 2 savings Recycler An An intelligent balance between Non Toxic and Circular Economy is required 13
14 Our recommendation for the interface Chemicals & Waste Legislation Some legal certainty and clarity is required to stimulate recycling Micro Management by EU recyclers of SVHC on parts level is unrealistic A database can be hugely helpful to create risk profiles for components or component groups But a recyclers can only de pollute risk profiled parts groups mentioned in WEEE or ELV annexes. Please consider this when designing a database. Recyclers don t count on markings to be correct Large volume recyclers cannot even look at them Dismantlers cannot assume that markings are correct The recycling industry needs Balanced thresholds of SVHC s based on impact assessments A risk instead of a hazard approach for SHVC s and POPs Not based on chemical s properties only But context based risk assessments see TV Housing. Legislation based upon recycling practices built around EU guidance. Let us take the IPPC recommendations serious Thank you 14
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