EAA COMMENTS ON THE THEMATIC STRATEGY: PREVENTION AND RECYCLING OF WASTE COM(2003) 301 final

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1 EAA COMMENTS ON THE THEMATIC STRATEGY: PREVENTION AND RECYCLING OF WASTE COM(2003) 301 final The European Aluminium Association is a member of Eurométaux (European Non- Ferrous Metals Association) who have submitted their comments to the European Commission on the Thematic Strategy. Due to the achievements of aluminium in the recycling sector, we are pleased to submit additional aluminium-specific comments. Recycling has become an integral part of the raw material supply and at the same time it offers ecological justification for the use of aluminium. Even critics have gradually come to realize that the recycling of aluminium is a success story both from an ecological and an economic point of view. Aluminium recycling is carried out on an industrial scale. We would like to outline that aluminium is widely used mainly in four major applications: (1) mass transportation, (2) building and construction, (3) packaging, and (4) automotive sector. We will provide more detailed recycling and prevention comments on building and construction, and in the packaging applications. But first we will briefly outline the issue of the availability of secondary raw materials. Availability of Secondary Raw Materials Secondary raw materials are recycled and used whenever it is reasonable from an economic and ecological point of view. European Standards CEN EN recognise aluminium and aluminium alloys as valuable scrap (see Appendix I). The total annual aluminium demand is estimated to be about 30 million tonnes worldwide 1. Current statistics record an annual production of recycled aluminium in the range of just less than 10 million tones worldwide, with production being based on both old and new scrap. The supply of secondary raw materials is of fundamental significance to the aluminium recycling industry. In contrast to the virtually unlimited availability of raw materials for the production of primary aluminium, the supply of secondary input materials is clearly limited and depends on the quantities of aluminium used and the different life-span of products. The volumes of secondary input materials consist of aluminium scrap quantities, which at the end of a product s service life become available for recovery and 1 Metal Statistics, , WBMS Figure. 1

2 recycling, and scrap quantities which arise during the production and processing of aluminium. Apart from sheet and profile scrap, turnings and dross play a key role. Aluminium scrap is a much sought-after raw material all over the world, and as a consequence, substantial volumes of scrap enter the international trade. As such, it is critical for the Commission to examine recycling issues from the different sectors from a global perspective. Over the last decades, the US, Europe and Japan formed a recycling triangle as the centres where the aluminium industry was concentrated. This is still the case but clear signs have emerged that the Chinese recycling industry in particular is heading for substantial growth and Europe is finding itself with less and less available scrap. Building and Construction The characteristics and properties of aluminium have lead to revolutionary and innovative changes in building techniques and architectural and engineering projects. Aluminium extruded, rolled, and cast products are used for window frames and other glazed structures (large roof superstructures for shopping centres and stadiums). Most recently aluminium has played a significant role in the renovation of historic buildings. In a recent report (October 2003) conducted by TU Delft, the final conclusions concerning the inventory of aluminium and the collection of aluminium during demolition of buildings in a selection of European countries (Germany, the Netherlands, France, United Kingdom, Italy and Spain) showed that the recycling rate for aluminium is approximately 95%. This landmark study aims to establish a system by which recycling figures for this sector are collected and appraised systematically. The study further concluded that aluminium collection and subsequent recycling is supported by: The scrap value of aluminium. The recovery of scrap is practised over a long period where a solid infrastructure is established that facilitates its collection and recycling. The level of workers payments. Scavenging of metal parts by workers is often seen on sites as it provides additional income. The shape, type of connection, mass and amount of specific aluminium items. Plates, bars, profiles, strips are collected if sufficiently large in weight. Mechanical processing with crushers: To improve the marketability of waste wood and rubble, cleaned size fractions are offered with specifications of purity. This separation process is beneficial to the recovery of aluminium, starting with in line hand picking, magnetic separation, eddy current separation and other devices. Specifically small aluminium items less than 100 g are recovered here (neglected during demolition). 2

3 Packaging and ELV Aluminium packaging tends to be a high-profile issue and numerous debates regarding decoupling economic growth from waste generation has emerged in the last few years. Aluminium packaging: Contributes to the efficient fabrication, storage, distribution, retailing and usage of many products. Provides optimal protection properties by offering an impermeable metal barrier to light, ultra-violet rays, water vapour, oils and fats, oxygen and micro-organisms (functional barrier). Hygienic, non-toxic, non-tainting and retaining the product s flavour. Keeps contents fresh and guarantees long shelf life (i.e: UHT milk). One of the main reasons why aluminium is used in packaging is because it prevents waste. Customers turn to the use of aluminium for its unique properties in preserving food, drink, medicines, etc. As well, aluminium packaging is easy to recycle. For example, the aluminium can is superiour in recyclability after use and makes a large contribution to energy saving. It helps to save natural resources. It also has a higher scrap value compared to other packages because of its properties: lightweight, high strength, effective barrier, etc. We welcome the Commission s statement to re-examine existing legislation, such as the Packaging and Packaging Waste Directive. In our opinion, the Directive is fixated on recycling rates. It is further flawed for the following reasons: Directive is end-of-pipe oriented; No scope for resource efficiency; No scope for weight savings linked to transport; No scope for energy savings; No scope for combination (packaging AND packaged product); No scope for material-specific properties; and No scope for country specific waste management situation. The environmental soundness of the aluminium beverage can is highlighted by the further increase in 2002 in its recycling rate throughout Europe at 46%. This high level of recycling has been achieved even in the midst of complexities as regards most of the multi-material collection schemes which can lead to a high degree of dilution for aluminium in the packaging mix thus rendering aluminium extraction more difficult. This is amplified by the fact that some of the collection schemes are still in their early stages of development. Nonetheless, the value of Used Beverage Cans (UBCs) has sustained the 42% recycling rate in the voluntary collection system in the UK and ensured the economic balance of the deposit systems in the Nordic countries, which tend to have the 3

4 highest recycling rates. The reason why such recycling rates are achieved, despite some difficulties mentioned above, is due to the fact that aluminium is the most valuable material in the waste stream. We would also encourage the Commission to examine how certain waste legislation has been implemented in the Member States. For example, in Denmark, incinerators are in intricate element in their waste management programme. Unfortunately, there are no incentives to recover aluminium from slag. The waste legislation should encourage operators to recover valuable waste streams, particularly in light of today s conditions regarding the declining availability of raw materials. Another area regarding policy inconsistent policy is the End of Life Vehicles (ELV) Directive. The ELV Directive actually negates many of the environmental aspects which the aluminium industry has strived to achieve. The ELV Directive requires 85% by weight recycling. The legislation dilemma affects the aluminium industry as follows (Table 1) : Table 1: Legislation Dilemma Small Car 1000 kg Weight of nonrecyclables Weight of recyclables Effect of legislation Conventional Built Accepted Light Weight Structure Not Accepted The illustration in Table 1 is an excellent example of inconsistent policy. The increased use of aluminium in vehicles leads to lighter vehicles which contributes to significant CO 2 emissions reduction. The current ELV discourages the use of lighter material. Light weighting of motor vehicles can reduce both fuel consumption and emissions of pollutants and greenhouse gases (GHG). We urge the Commission to rectify these inconsistencies. 4

5 Table 2: Aluminium Beverage Can Usage and Recycling 2002 Country Total can usage 1 Alucan usage 1 Alu share (%) Recycling rate (%) Austria Benelux Denmark / / / / 4 Finland France Germany Greece Ireland Italy Norway + Iceland Portugal Spain Sweden Switzerland Turkey United Kingdom Total Western Europe Poland Other Eastern + Central Europe and unallocated n.a. GRAND TOTAL n.a. N.B. These figures are estimates compiled by the aluminium industry since most countries do not record beverage cans separately, except those countries which have deposit (or similar) schemes. 1 In million units 2 The quoted recycling rates refer to the estimated results of the recycled aluminum packaging fraction 3 In Belgium and the Netherlands, all metals recycling is counted as one fraction: preliminary data 4 Cans were introduced on the Danish market in late 2002, DRS (Dansk Retur System) official figures will appear for the first time in late Latest official result for the recycled aluminium packaging fraction 6 Taking into account uncertainties of some figures 5

6 Efficient Recycling Technology Our mineral processing, smelting and casting plants, which have involved a vast amount of development work, represent the latest in international technology and enable the sector to recycle aluminium cuttings and dross along with many other types of aluminium scrap in an environmentally friendly way (see Appendix I). Over recent decades aluminium has assumed a leading position among casting metals because in addition to its acknowledged advantageous properties, it also offers the widest possible variety of casting and joining processes. Their almost unlimited recycling capacity also makes aluminium casting alloys distinctly superior to other casting metals. Achieving a balance in the material flows for every batch or production run contributes to the continuous optimisation of our processes. Minimising the loss of valuable aluminium across the entire recycling process is the ultimate goal. In order to achieve this goal, the industry is constantly developing new production and logistical concepts often in collaboration with customers. The aluminium recycling industry views developments and advances in process engineering and the optimisation of production processes, and those of customers, as both a strategic necessity and an opportunity. Example of Aluminium Recycling Process Ingots are cast by tilting the holding furnace and pouring the molten metal - via a twostage process to remove any remaining minute non-metallic particles and gases - into a vertical casting unit. Chemical composition and metal cleanliness are then tested on each cast. As the metal flows into the mould, it is chilled by jets of cool water being pumped around the mould, and a solidified outer shell is formed. The base of the mould begins to lower hydraulically, the metal continues to flow into the mould and the shell is now directly cooled by a secondary water curtain as the ingot grows to a length of up to 9m. 6

7 Conclusions Aluminium has unique recycling qualities particularly the fact that the quality of aluminium is not impaired by recycling as it can be repeatedly recycled. Aluminium recycling saves an extraordinary amount of energy. Remelting used aluminium saves up to 95% of the energy needed to produce the primary product. As such, aluminium recycling is economical since it uses less energy and recycling is self-supported because of the high value of used aluminium. The industry objective to increase the percentage of recycled aluminium used is part of a suite of options to reduce energy demand. The recovery of aluminium for reprocessing also employs many people who rely on its steady commercial value as a means of making a living. While some sectors, such as aluminium packaging for recycling has a rate of return within months, others, such as buildings and engineering uses, only return the product for recycling after decades. The average return period of about twelve years corresponds to the average life of an automobile. There is no intermediate return or replacement as the corrosion-resistance of aluminium assures long life without maintenance this in itself energy saving. The net energy use of the aluminium life cycle is overwhelmingly advantageous to sustainability. Aluminium helps attain overall recycling targets due to its unique recycling performance and intrinsic value. Aluminium is recognised by scrap merchants and recovery organisation as the most cost effective material to recycle. The aluminium industry is developing and continuously improving its recycling processes. This ensures that aluminium maintains its position as the most valuable material that can be recycled. Investing in improving recycling technologies ensures that we can recycle more aluminium and therefore gaining substantial savings. Aluminium has been recycled since the days it was first commercially produced and today recycled aluminium accounts for one-third of global aluminium consumption worldwide. The recyclability of aluminium assumes a twofold significance. From an economic perspective, aluminium is a renewable material, which simultaneously serves as an energy bank. The energy needed initially to extract aluminium metal remains stored in the metal. All subsequent recycling processes do not require this amount of energy once again, but content themselves with the energy that is necessary for the treatment and melting of the aluminium containing secondary raw materials. This element is recognised in the Thematic Strategy where it states that recycling 1 tonnes of aluminium saves 9,100 kg of CO 2 equivalent (page 12). Regarding future perspectives, due to the increasing use of aluminium, there will be more aluminium to be recycled. The volume of recycled aluminium determines the capacity of primary aluminium production. This aspect needs to be recognised by the Commission and we urge policy coherence in order to stimulate recycling for our sector. Due to its recycling performance, aluminium fulfils many sustainability requirements. The EAA is currently developing sustainable development indicators which will be 7

8 available in early We hope to demonstrate the efforts our industry has undertaken in recent years both from a SD point of view and as a viable European competitive sector. Nonetheless, we continue to face challenges such as the availability of secondary raw material (aluminium scrap) in Europe which is in danger for it is being exported to China and India in rapidly increasing quantities under distorted market conditions. Europe will soon be faced with a shortage if this trend continues. In conclusion, the aluminium industry is focusing on recycling in the context of increased global demand for used aluminium. Economic and environmental qualities of aluminium help meet targets set by stricter environmental legislation and make aluminium the material of choice by consumers. Grace Barrasso 8/12/03 barrasso@eaa.be 8

9 APPENDIX I EN : Aluminium and Aluminium Alloys Scrap Part 1 : Part 2 : Part 3 : Part 4 : Part 5 : Part 6 : Part 7 : Part 8 : Part 9 : Part 10 : Part 11 : Part 12 : Part 13 : Part 14 : Part 15 : Part 16 : General Requirements Unalloyed aluminium scrap Wire and cable scrap Scrap consisting of one single alloy Scrap consisting of two or more wrought alloys of the same series Scrap consisting of two or more wrought alloys Scrap consisting of castings Scrap consisting of non ferrous materials from shredding processes destined to aluminium separation processes Scrap for aluminium separation processes of non ferrous materials Scrap consisting of used aluminium beverage cans Scrap consisting of aluminium-copper radiators Turnings consisting of one single alloy Mixed turnings of two or more single alloys Scrap from used post-consumer aluminium packagings Decoated aluminium scrap from post-consumer aluminium packagings Aluminium scrap consisting of skimmings, drosses, spills and metallics 9

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