A number of the plastic recycling industry’s key players have published a ‘wish list’ of actions which would accelerate the transition to a circular model for complex durable plastic products.
The document summarises the shared opinion of some key players regarding complex wastes such as End-of-Life Vehicles (ELVs) and Waste Electrical and Electronic Equipment (WEEE).
It highlighted a number of the market drivers for change needed to promote a transition towards a ‘true’ circular materials economy in the industry.
Penned associations, the BPF, EuRIC, and EERA and plastic recycling firms, MBA Polymers, Axion Polymers, GALLOO and Müller-Guttenbrunn Gruppe, the document noted that in the next two years we there will be an increasing level of discussion and debate about the shape of the EU’s Circular Economy Package.
In this context the authors said that the Wish List should be seen as a plea to leaders, innovators and key influencers involved in that debate by setting out a simple set of measures that will help to drive change in a positive direction to promote the Circular Economy.
Key Facts
Automotive – The wish list explained that there are an estimated approximately 275 million motor vehicles registered for use on the road network of the EU member states and this represents an impressive urban mine of materials. New vehicle production continues to grow steadily with quickly changing technologies.
The average mass of each new motor vehicle is approximately 1.3 tonnes, of which currently about 20-25% consists of plastics or elastomer material which is made primarily from non-renewable oil- based resources.
The annual plastics consumption for the car industry in Europe is close to 4 million tonnes per annum. The currently reported quantity of End-of-Life Vehicles (ELVs) consists of 6.3 million ELVs per year and this represents a quantity of ELV plastics of some 1.2 Million tonnes.
It is estimated that the potential for use of Post-Consumer Recycled (PCR) plastics used in new-build cars can be as high as 5% of vehicle mass, which would have a huge environmental benefit.
Electrical & Electronics – The quantity of Waste from Electric and Electronic Equipment (WEEE) was said to constitute some 9.5 million tonnes per annum, of which quantity approximately 5-6 million tonnes are being recycled in Europe. Some 1.2 million tonnes of this material are plastics materials.
According to the document technology exists to recycle over 50 % of this material into Post-Consumer Recycled (PCR plastics) and the remaining quantity which cannot be recycled as material can be used for energy recovery.
The authors also noted a recent Life-Cycle Analysis comparing the production of virgin plastics with the production of PCR plastics illustrates the benefits of using PCR plastics.
The total demand for plastics for the production of Electric and Electronic Equipment (EEE) is 2.5 million tonnes per annum.
The practical application of PCR plastics for the production of new Electric and Electronic Equipment was said to have been proven in a significant number of cases.
Current Materials Recycling Model
The producers of automobiles and electronics across Europe have been given the responsibility for the end-of-life capture, collection and recycling or recovery of the products that they put on the market.
The document explained that under this Extended Producer Responsibility (EPR) legislation the focus is placed upon ‘polluter pays’ by making branded manufacturers and importers share the financial burden of the cost of waste collection and recycling.
However, it also noted that there are several variations on the way this is implemented across Member States, but most link the brand’s current market share in tonnage terms to the cost of collection, treatment and recovery measured at the point of waste collection, which responsibility is outsourced to take- back or similar systems in many of the cases.
Current legislative measures have already placed high targets on the percentage of end-of-life products that must be recycled or recovered.
The authors went on to explain that the European ELV directive prescribes a total recovery rate of 95% of which 85% as (material) recycling rate and the European WEEE directive as varying recovery and recycling targets depending on the category of WEEE and these targets are growing over time. Consumer Electronics and IT currently have a recovery rate target of 80% with a (material) recycling rate of to 70% and Large Domestic Appliances 85% recovery and 80% (material) recycling rate.
However, according to the document this ‘arms-length’ approach to ‘responsibility for end-of-life’ failed to create a circular flow of recycled materials back into new products.
Most manufacturers were said to have transferred their responsibilities for collection and treatment to take back schemes. The collection and treatment is considered a cost factor and therefore continuous price pressure on these services is eminent.
Their compliance with the Directives was claimed by the authors to have become an annual accounting exercise.
The document argued that there is virtually no involvement by product designers, materials purchasers, marketing managers, production engineers in the process of satisfying end-of-life product responsibility. The disconnect between the return flow of materials – take-back, collection and recycling - and the design, procurement and sales of new durable products can be seen as the “missing link” in the Circular Economy.
The long lifetime of products in the vehicle and electrical goods markets (i.e. two to 20 years) was found to means that there is a long delay between making a product and that item reaching its end-of-life stage, where the materials can be captured, separated and recovered for recycling or reuse.
This was said to increas the level of ‘disconnect’ between those people involved in design and development of new products and the growing industry involved in recycling of materials from old products (unlike packaging materials, where the working lifetime is measured in days or weeks and forward thinking businesses can get very rapid benefits by tapping into the readily available flow of plastics materials being recycled from household waste collections).
The authors argued that product manufacturers are to a great extent still operating a linear model for sourcing and use of raw materials to create a this growing volume of durable products.
According to the Wish List this huge mountain of durable goods - destined to enter the waste stream at some stage in the future - represents a predictable, know composition urban mine of material that could and should enter into an efficient collection and recycling infrastructure that is laid out to deliver these materials back into manufacturers as a sustainable and stable flow of Post-Consumer Recycled secondary raw materials.
According to the document the plastics recycling industry for these complex raw materials is capable of producing products that comply with product legislation.
However, the ever changing thresholds for an ever increasing amount of substances under REACH and POPS legislation are said to form a considerable burden for this new industry with a risk that the investment levels will come to a halt.
Legacy issues, the report said, require a holistic approach starting at product design stage. Whilst the industry is capable of reducing the legacy of substances to the greatest possible extent, the recycling industry will not be able to eliminate all substances of concern completely.
The document called for this to be recognised whilst setting new thresholds for raw materials, whereby it is important that there is an alignment of these thresholds for wastes and for products. For some substances reasonable exemptions for recycling might be required.
Continuously changing threshold values for ever more substances in the EU legislation were said to impact the development of a recycling industry infrastructure negatively and hence have a negative impact on the development of a recycling society and circular economy that the EU Commission is seeking.
Today many of the valuable raw materials embedded in these durable goods are still exported out of Europe, often illegally, said the document.
The European Waste Shipment Regulation’s rules on notifications of “non- listed wastes” - many of the mixed materials from these durable goods are considered to be notifiable wastes – sets rules and procedures to the transboundary shipments of these raw materials were said to often be prohibitively complex, long and expensive. Rule and procedures for these raw materials are the same as those required for most hazardous wastes.
The report argued that because of this much of this potential input for compliant European recyclers therefore leaves the European Union, as the enforcement of these rules for the export out of the EU is virtually non-existent.
While many innovative, entrepreneurial, technology leaders have taken the early-stage steps to invest in the new processing industry to recycle these durable end-of-life products, the authors said that there is now a great opportunity to capitalise on the learnings and experience of those ‘first-movers’ and to help catalyse a transition across the sector to a much more circular material flow economic model.
With a combined experience of over 25 years of operating within the EU and global recycling industry for these products, the authors have shared the following ‘wish list’ of principles that should be included in any new set of measures and legislative instruments put in place to help deliver a circular economy in the sector.
The Plastics Recycling Industry Wish-List
Procedures for the procurement and transboundary shipment of complex mixes of raw materials for the production of secondary raw materials by compliant recyclers within the EU should be made easier, quicker and cheaper. Pre-consented and verified facilities within the EU have a special status, which should be recognized by the competent authorities in country of despatch. A FAST-TRACK NOTIFICATION procedure should be developed to allow these compliant recyclers to get better access to these complex input materials from other countries within the EU.
The primary focus of any new measures should AIM AT PULLING THE DEMAND FOR Post- Consumer Recycled content in order to convert the linear supply chain to a circular material flow model. The industry already has high targets in place for the collection of end-of-life products and with high recovery and material recycling targets set in those regulations. The missing link in the Circular Economy is the communication between the recycling companies and the producers of durable products – the Circular Economy Package should encourage this by rewarding the incorporation and use of traceable Post-Consumer Recycled (PCR) content back into new products. This could take the form of:
Public Green Procurement rules to enforce a change towards products that contain well-defined quantities of PCR content. This to cover durable product purchases, electrical and electronic goods, vehicles and construction materials in addition to the ‘easy-wins’ in short life consumables such as printing paper, packaging (Example – EPEAT in USA federal law).
Private sector – drive Member states to implement positive, reward-based drivers to encourage product manufacturers to specify and use recycled materials (especially plastics). Measured and proven levels of PCR use should be encouraged by positive benefits accruing to those companies who make the changes (e.g. increased R&D and/or capital investment tax allowances linked to higher levels of traceable PCR content in new products).
Enabling this to happen in Europe
One key area that needs to be recognized during the envisaged ‘transition period’ from a linear manufacturing economy to one that embodies CIRCULARITY, is a pragmatic recognition that the huge urban mine of materials that is already in place will contain some materials and additives that are no longer seen as desirable in modern materials (i.e. at least 15 years of in-use cars or some electronic products to be processed when reaching end-of-life).
The legal situation that applies to the recycling industry with both waste and product legislations that apply (REACH, ROHS for products, POP, WSR, WFD for waste) is extremely complex. For example, the Waste Framework Directive does not allow any mixing of materials with the purpose to reduce the levels of these substances of concern.
Technology is available to produce secondary raw materials made from durable goods that meet current product legislations. However legal initiatives and thresholds for particular substances change continuously. There are pressures to define new thresholds for certain substances – such as some brominated flame retardants - to levels beyond those that can be measured reliably or to levels that can be reached technologically for secondary raw materials.
The recycling industry therefore calls for realistic THRESHOLDS for substances of concern and for a continuous exchange of views between the legislator and the recycling industry if changes are planned. In some cases, a solution can be found by creating exemptions for certain thresholds for PCR materials for well-defined periods of time. In other cases, the most desirable route forward is to re-incorporate the captured plastics containing such additives back into new long-life products (e.g. stabilizers in PVC window frames).
Therefore, a key addendum point in the industry wish-list is:
Regulators across member states to take a pragmatic and balanced approach to the allowable levels of residual trace legacy additives remaining inside recycled plastics during the extended period of transition to a circular material flow. (maybe next 10 – 20 years)
Set levels of allowable trace chemical additives that are realistic in terms of the risk posed and sensible in terms of actually being detected by laboratory instruments in general use.
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