EuRIC : Advocating recycling in Brussels BVSE JAHRESTAGUNG 13 September 2017, Potsdam. Emmanuel KATRAKIS Secretary General, EuRIC

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1 EuRIC : Advocating recycling in Brussels BVSE JAHRESTAGUNG 13 September 2017, Potsdam Emmanuel KATRAKIS Secretary General, EuRIC

2 Our Members The European Recycling Industries Confederation (EuRIC) brings together recycling federations from 20 EU & EFTA Member States and represents: 6,000 companies, many of them SMEs. 300,000 local jobs. 150 million tons of waste recycled/year. An annual turnover of about 95 billion.

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5 Our structure EuRIC is a multi-material recycling industry organisation EuRIC Umbrella Organization Cross Material Issues Ferrous Recycling Branch (EFR) Non-Ferrous Recycling & Trade Branch (EUROMETREC) Paper Recycling Branch (ERPA) Glass Group and new streams ESG (Shredders) WEEE

6 Your Representation, Our Daily Mission Advocate the interests of European Recyclers Be your voice in Brussels Act as the trusted interface between European recyclers & traders and the EU Connect you with EU decision-makers Serve as a forum for information and cooperation about Recycling Foster information exchange throughout European recycling community Connect Members & the industry Inform & advice (expertise) Lobby EU institutions Gather and share facts & expertise

7 Making a difference for recyclers Waste (not a burden) = Resource Less administrative burdens = more recycling! Recycling Circular / Resource efficient Recycling saves Energy & CO2 Industry: market supply & demand Business-friendly measures Free and fair trade

8 EU Institutions The European Commission EuRIC advocacy Submits proposals Decision-making process The European Parliament The Council of the EU EU agencies, JRC (EU IPPC Bureau), CEN/CENELEC, Committees, etc.

9 Chemicals Legislation / Waste Legislation Chemicals legislation CLP Regulation (EC) No 1272/2008, REACH The waste exemption, cf. Article 1(3) of CLP Regulation: Waste as defined in the Waste Framework Directive on waste is not a substance, mixture or article within the meaning of Article 2 of this Regulation List of HP (Hazard Properties) 1 to 15 criteria to classify waste (Hz/Non-Hz) NB! However, waste is regarded as a mixture of substances. Waste legislation List of Waste, cf. Decision 2014/955/EU, cf. Annex III WFD Related to materials (waste stream), eg. Packaging, WEEE, ELV. NB! HP criteria NB! Holistic approach for collection, transport, treatment and storage

10 Chemicals Legislation / Waste Legislation Mixture of substances: Plastics Ferrous Non ferrous Glass Wood Paper and Cardboard Plastics: PE, PP, PS, PC, ABS, PA 6 Polystyrene: Styrene Hexabromocyclododecane Diantimony trioxide (Sb 2 O 3 ) Dibromostyrene Polybrominated diphenylether Ecotoxcity: Biosystems (water, soil, air) Holistic approach: Collection, i.e. WFD, LoW, WEEE Transport, i.e. ADR/RID Treatment, i.e. WFD, LoW, WEEE Storage, i.e. LoW, WEEE Recycling, WEEE, CLP Products, i.e. REACH, CLP Treatment: Secondaries Hazardous residual wastes Non-hazardous residual wastes Secondaries: Plastics Ferrous Non ferrous

11 Chemicals Legislation / Waste Legislation Mixture of substances: Plastics Ferrous Non ferrous Glass Wood Paper and Cardboard The holistic approach by waste mangement results in Secondary materials Hazardous residual wastes Non-hazardous residual wastes Matrix Plastics varying in its composition and toxicity. Improving the interplay between waste and chemical legisations needed to boost circular flows Problems from CLP (REACH) application: describes relative static systems Ecotoxcity: Biospehre, biosystems (water, soil, air) Only the waste legislation describes dynamic systems, which are matrix determined

12 Value Value Waste Legislation / Chemicals Legislation Mix of articles (waste) Mix of materials Recovered materials Complexity of the streams Articles Materials Substances Complexity of the streams Logic of recycling Logic of retail

13 Example: HP 14 (ecotoxic) Commission proposal adopted under «comitology procedure» Classified as ecotoxic waste which contains: Ozone depleting substances c(h420) 0.1% Aquatic acute substances [ c (H400) 25 % ] H420: 4 substances H400: 1097 substances H410: 987 substances H411: 569 substances H412: 406 substances H413: 252 substances Aquatic chronic 1 (H410), 2 (H411) or 3 (H412) [ 100 x c (H410)) + 10 x c (H411) + c (H412) 25% ] Harmonised M-factors For some of these. Aquatic chronic 1, 2, 3 or 4 (H413) [ c H410 + c H411 + c H412 + c H % ] Calcultion method ignores waste inherent specificites

14 Photo: consilium.europa.au

15 EuRIC Position HP 14 Criteria The case of Fluff-light fraction and dust from shredding of metal waste (WEEE & ELVs) Heterogeneous stream arising from ELVs and WEEE recycling Treatment and post-treatment enables safe and valuable recovery Metals Dedicated metal recycling facilities Mixed plastics Dedicated plastic recycling facility Residual waste WtE (organic fraction) / Landfill mineral fraction HP 14 Study carried out by INERIS & Bio by Deloitte There is no evidence of pollution with contaminated fluff and dust (p. 116, section ). Reclassification risks disrupting well-functioning recycling chains Unassessed substantial costs increase + capacity shortages Limited dataset to draw conclusions based on scientific evidence Shared responsibility of all stakeholders, including industry

16 EuRIC Position HP 14 Criteria Methodology solely based on chemical analysis not suited for all streams as explicitly acknowledged by the HP 14 Study (pp. 61 & 62): Approaches based on chemical analyses are easy and satisfactory for welldefined samples whilst uncertainties regarding the composition of waste is the main limit of approaches based on chemical analysis ; Biotests ( ) are useful in assessing very complex matrices, having many constituents, which are very difficult or impossible to be determined by chemical analysis; Explicitly allow for alternatives, in particular biotests, more suited to complex streams to assess waste for HP 14 property Positive reference to tests in the Draft Regulation List of waste (LoW) clear provision in Annex: Where a hazardous property of a waste has been assessed by a test and by using the concentrations of hazardous substances as indicated in Annex III to Directive 2008/98/EC, the results of the test shall prevail.

17 EC consilium.europa.au Audiovisual services Photo:

18 Waste & chemicals in the circular economy Looking ahead Interface between waste & chemicals must be addressed at source, not only when products reach EoL stage More information needed about substances incorporated into products to ease proper treatment. Improved interface between waste & chemicals must incitivize safe use of recycled materials and level the playing field with virgin materials EuRIC provided a very comprehensive response (13 pages) with many practical examples provided by Members to the public consultation run by the European Commission in July 2017 (soon available online)

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20 Thank you for your attention and see you in.milan on 5/10!