REACH, Circular Economy (incl. Waste Framework dir.) Hugo Waeterschoot and Violaine Verougstraete, 4 September 2018

Transcription

1 REACH, Circular Economy (incl. Waste Framework dir.) Hugo Waeterschoot and Violaine Verougstraete, 4 September 2018

2 Closing the loop Closing the loop through reuse or materials recycling improves the performance of substances exponentially! 2

3 Non Toxic Environment

4 The idea is not new the increased attention is! Pg.4

5 Non-Toxic Environment: regulators perspective 2018 EU Non-Toxic Environment the development of sustainable substitutes including nonchemical solutions Non-Toxic Environment: industry s perspective Europe s metals industry is committed to achieve a riskcontrolled environment, where all exposure to human health and the environment is controlled Pg.5

6 BUT how to resolve this for metals & inorganics? Promotion of a risk-controlled environment Our vision is of a fully riskcontrolled Europe, where hazardous substances are used only when certain they will not harm human health or the environment Pg.6

7 Work out:

8 Chemicals/Waste/products Interface

9 Aims of the Chemicals/Waste/interface "Closing the loop - An EU action plan for the Circular Economy" the intention to undertake an "Analysis and [prepare] policy options to address the interface between chemicals, products and waste legislation, including how to reduce the presence and improve the tracking of chemicals of concern in products" as a means to develop policies that can deliver circular economy through a seamless flow of materials recycled from waste as suitable raw materials back into the economy.

10 How to keep Materials in the Societal/Industrial cycle in a safe way Pg.10

11 Chemicals Product Waste Interface In practice. for inorganics Pg.11

12 Closing the loop: from a MATERIALS PERSPECTIVE INPUT MANUFACTURING OUTPUT Recycling products Issue: narowness of the UVCB description Hampers access to RM Waste Materials Tracability not much of an issue for metals but boundaries of waste/substance Interphase are Pg.12

13 Minimise-Optimise-Maximise Recycling of metals: how does it work? Whatever enters the flowsheet leaves as refined metal, final slags or waste material Recyclables Collector metals different metals and metal compounds slags Ind. Waste disposal Industrial by-products Pg.13

14 Closing the loop is more and more important but also more and more difficult Pg.14

15 But there are technical constrains Base metals Cu, Pb, Ni, Sn and Zn and their processing infrastructure all play a crucial part in present society acting as enablers in any recycling efforts, as they carry and release important and vital minor elements. Of importance is not only the criticality of elements but also the criticality of the metallurgical infrastructure and technology that enables the economically viable recovery of elements and compounds from complex products and materials (Markus A. Reuter (Prof. Dr. Dr. h.c., Lead author of the UNEP report on metal recycling) UNEP (2013) Metal Recycling: Opportunities, Limits, Infrastructure Pg.15

16 CPW Interface documents Chemicals/Products/Waste (CPW) Interface EC Communication Contains general prescriptions Lists some additional questions to stakeholders EC Staff Working Document (SWD) Lists specific options to choose from No policy measures proposed, only some new reports PUBLIC CONSULTATION is RUNNING until 29 October Pg.16

17 CPW Interface 4 areas and 8 challenges Insufficient info about substances of concern in products and waste Challenge 1: Defining substances of concern Challenge 2: Tracking substances of concern Addressing the presence of substances of concern in recycled materials Challenge 3*: Level playing field between secondary and primary material Challenge 4: Level playing field between EUproduced and imported articles Challenge 5*: Design for circularity Uncertainties about how materials can cease to be waste Challenge 6*: Improving certainty on the implementation of EoW provisions Difficulties in the application of EU waste classification methodologies & impacts on the recyclability of materials (secondary raw materials) Challenge 7*: Approximating the rules for classification of chemicals and waste Challenge 8*: Classifying waste taking into account the form in which it is generated Challenge(*) = SUS COM (incl. SRM WG) expertise will be sought Pg.17

18 CPW Interface: feedback from the Circular Economy Stakeholders Conf. (02/2018) Main issues identified in the public consultation (2017): 1) Limited information on substances of concern used in articles EC action: develop a specific methodology for calculating costs and benefits of using recycled material 2) End of Waste issue EC action: develop a platform to facilitate online interaction and a more consistent interpretation of EoW across the EU 3) Lack of consistency across the EU in application & enforcement of classification of waste streams containing substances of concern EC action: publication of a guidance document for a common approach to be applied by the MS Competent Authorities Pg.18

19 CPW Interface: feedback from the Circular Economy stakeholders consultation Additional aspects raised in the discussion: Improvement of data flow (from substances to articles; from articles to waste) Collaboration between producers and recyclers already at the design stage Introduce authorisation for imported articles containing substances of concern Closer alignment between CLP classification and waste legislation Pg.19

20 Chemicals, Products and Waste Interface Conclusions: the CWP interphase, should: - Demonstrate safe use independent the status (subst./product/waste) - start from the industrial/economic reality - be careful in stating generic recommendations/actions given the organics, inorganics and other material flows are very different and require different attention - promote a level playing field to ensure an open market - help eliminating incorrect practices (e.g. products considered as waste thereby restricting their demonstrated safe use) Pg.20

21 P Do we (really) need a trade off?

22 Large economic/societal trends. Will they be influenced by REACH or the Circular Economy? But what about product safety: Co, Ni, Li, Al, = REACH But what about the end of Life : Battery (recycling) Directive

23 CONCLUSION: think more holistically eg by integrating 4 important EU policy perspectives WASTE Minimising losses and disposal ENERGY efficiency & CLIMATE goals Minimise energy use and maximise energy material content METALS Technical use Maximise Life time and performance efficiency? REACH Ensure safe manufacturing supply and use Circular Economy Strategy Can we extend life time and closing the loop?

24 THANK YOU but especially More information, contact: - verougstraete@eurometaux.be - Waeterschoot@eurometaux.be Avenue de Broqueville 12 B-1150 Brussels Tel: +32 (2) eurometaux@eurometaux.be