Recycling : Drivers and Dilemmas of Recycling

The curated session of the ISWA Working Group on Recycling and Waste Minimisation (WGRWM) brought together seven senior professionals (including the Chair and the Moderator, listed above, who are working in and researching recycling and waste management, and invited them to share their views and experiences in a 90-minute facilitated discussion on the state of the art in recycling in 2021.

The session chair, Dirk Nelen of VITO in Belgium, organised the session around the question: what drives recycling? The session served as a high-level discussion of what recycling is and is not in the 21st century, what motivates cities, towns, companies and the value chains to recycle, what the barriers and problems are to recycling, and what the relationship is, if any, to the circular economy discourse in Europe and the zero waste ‘movement’ in North America.

There is little disagreement about the fact that the public sector’s role in the management of solid waste is the result of a long history of public health law and closely associated with the imperatives for maintaining public health in relation to both urbanisation and industrialisation. The role of recovery and valorisation is woven throughout this history, with more recycling when the waste materials or human or animal excreta are in demand by industrial or agricultural sectors, and less when there is a public health crisis and a strong demand for sanitation and cleanliness (such as at the time of writing, in relation to the COVID-19 pandemic).

This article outlines the main points of view expressed by the seven professionals and brings them together in a work stream and research agenda that the WGRWM will be pursuing in the coming two years.

What is recycling? What we know and what we don’t know

In essence, recycling refers to a series of activities and processes that result in the production of secondary materials of a quality that allows substitution of primary raw materials. The feedstock for the production of secondary materials consists of discarded, littered, or disposed products and packages and anything else found in waste. The potential sources of secondary materials include, in the broad sense, buildings, vehicles, packaging, infrastructure, consumer goods, household products, coatings and paint, chemicals and medicines, material goods used in services, and remains of plants and animals (to name but a few). The recycling process results in the generation of a secondary raw material, fit to be reused as recycled content in production processes.

In most countries at most periods of time, the ‘default’ driver for recycling is the demand for recyclables under the influence of supply and demand dynamics of a commodity market. Such market demand, sometimes called the ‘market pull’, can be formal or informal and local or global. This driver is always present in the background, whether or not protection of public health and the environment are policy drivers or not.

An interesting contribution to the session was the view that even demand-driven recycling doesn’t start at the gate of a recycling facility, but before. ‘Before’ has many levels:

1. at the time of production, when the design of the product determines what types and levels of recycling will be feasible, including decisions on product architecture and material choice.
2. in the multiple phases of packaging, ranging from packaging for individual items or servings; packaging for multiple items (such as a six-pack of beer); and distribution packaging, such as pallets and big bags, which are used in the distribution processes, all of which depend on how products are stored, transported and distributed.
3. in the use phase, depending on whether
    the product is used for the purpose for which it is designed,
    that use is light, ‘average’ or intensive,
    there are instructions for processes to maintain the product to keep it functioning as designed,
    it is regularly maintained according to those instructions,
    parts and components can be replaced,
    the product and its parts and components are repairable, and
    the user is in a place that has options to repair it.
4. when and how the last user or their recycling or waste service provider decides to discard it:
    in a ‘right place’ in their own country or city, such as a recycling bin for separate collection; a recovery system for organic waste or spent frying oil; an EPR (Extended Producer Responsibility) or DRS (deposit return system) collection unit for drink packaging, batteries or electronic devices; pesticide containers; pallets; or metal or plastic drums;
    in a ‘non-optimal’ but legal place in their own country or city, such as their own residual waste, someone else’s residual waste, a litter basket or a dumpsite;
    in a ‘wrong place’ in their own country or city, such as in a forest or in the river or a trash heap in their village;
    in a semi-formal system for second-hand trade, such as eBay or a flea market; or
    via another channel that results in that product or package being exported to another country or city, in which case there are all of the same right, non-optimal or wrong places as in their own country.

Moreover, there is a great deal of confusion between two sets of concepts:

1. illegal vs legal transport of waste or recyclables, and
2. waste materials destined for treatment or disposal (for a fee) vs recyclable materials destined for trade to an end-user industry.

So for the purposes of this article:
Legal transport is that which follows the rules of international transboundary regimes (such as the Basel Convention), including a manifest (list of what is being transported), complies with requirements of both exporting and importing countries, and correctly classifies the materials being transported as to whether they are waste or recyclables or products. Inspection can verify whether export is illegal or legal by comparing the actual materials to the manifest, and checking whether the transport is correctly registered.

Illegal transport is transport which violates or seeks to avoid compliance with the rules of either importing or exporting countries or transboundary regimes, has incorrect or falsified documentation, or transports materials which are not allowed to be transported.

In terms of the differences between waste on the one hand and recyclables and secondary materials on the other hand:
Waste and waste materials are those which are being removed because they are not wanted or needed or because their end of life has been reached, and which are destined for disposal or treatment without further use.

Recyclables and secondary materials are those for which there is a demand for the material (or in some cases the discarded product) by individuals, or by industry or agriculture, which have a value, and are being traded because of their value.

Who ‘owns’ recycling and who owns the materials to be recycled?

In the USA and most other places in the world, outside of Europe, the private recycling sector (that is, companies whose main business is processing recyclable materials, excluding waste collection, disposal, and incineration companies) is the major industrial and large-scale player. The geographic centre of this industry is in East Asia, according to a report by the Bureau of International Recycling: “Asia accounted for some 43% of world recovered fibre production, Europe approaching 27% and North America nearer 21%” (https://www.bir.org/publicatio..., downloaded in January 2022).

Manufacturing industries buy secondary materials based on industry-specific material specifications according to what is needed for production. Good examples are given by the ISRI Scrap Specifications Circular (http://www.scrap2.org/specs/2/), which offers guidelines for non-ferrous scrap, ferrous scrap, inbound kerbside recyclables, glass cullet, paper stock, plastic scrap, tyre scrap and e-waste; the Deutsche Kunststoff Recycling (DKR) specifications for plastic-containing wastes; and the UK PAS-103 specifications on waste plastic bottles and polythene film. For markets of secondary materials for which specifications and quality criteria are in place, per tonne prices are published in weekly or monthly time series. Indicative prices based on input from a range of businesses in the recycling industry are available online, at websites such as https://www.letsrecycle.com/pr..., which give an indication of the prices to be paid by medium to large-sized buyers.

The global recycling industry believes that it owns itself! The Bureau of International Recycling (Bureau International de la Récupération) is located in Paris, with an office in Brussels, and is the trade association of this global industry. It represents the formal industries and businesses that trade and use recyclables and secondary materials. There is some overlap between the BIR main constituency of recycling end-user industries, and the waste management service businesses which remove and transport waste, represented by ISWA, based in Rotterdam). Within the recycling industry, these trades are based on the commodity value of the materials, and they are almost always financial transactions where the buyer pays for the secondary materials.

In many countries and cities, the modernisation of the solid waste system has produced a national or regional solid waste law in which the ownership of waste is defined and allocated to specific stakeholders. This can help answer the question “who owns the materials?”, although it complicates the question of “who owns recycling?”. Some examples:

• In many cities and countries, the owner of the place or container in which the materials are found, at a particular time, is automatically the owner of the waste or materials. So, a waste company owns and is responsible for everything in its containers. Really? What if nuclear waste or a dead body is found in their containers? What if a diamond ring or a stolen artwork is discovered in a waste bin?
• With recycled material, at what exact point does the ownership pass from the generator, who owned the discarded product, to the recycling or waste company? When they put it into a bin or out on the street? When it is in their garage or closet waiting to be delivered to the charity shop? What about when bottles or cans which are eligible for a deposit return fee are found in a waste heap by the side of the river?
• Copper mine model: Does the owner of the mine own the copper? Or the holder of the mining concession? Or the refining company? What is the point at which the State, the institution that grants the concession, hands over the ownership of the copper to be extracted to the mining company? Is it only the copper or does it include any valuable metal or mineral that is present at the mining site? Does ownership of copper imply ownership of excavated waste rock? At all of these stages, elemental copper is not separable from rock and chemicals are used to extract it. When does it ‘definitely’ become copper and who has the right to commercialise it? What does this model tell us about waste ownership? In particular, what does it tell us about the fate of recyclables in an MRF or other sorting process? Who owns the ‘good’ valuable materials, who owns and has to manage the residues? And who pays for what?
• Once a material enters the waste stream, does the material belong to the party that does the collection or the party that pays for the collection? So if separate collection of glass is a paid service, does the glass belong to the municipality that pays the costs of collection, or to the private or public entity whose trucks are actually carrying the materials, or to the glass mill that has contracted for it to be delivered?
• In places with (Extended) Producer Responsibility, there are laws that require producers to form an organisation and organise their products’ end-of-life management. In some countries this is interpreted to mean that they are required to pay for the complete collection, sorting and recycling activity chain. But if recycling belongs to the recycling industries, what should they pay for?
• In the Netherlands, via a national EPR system, importers of automobiles or office paper are responsible for managing the waste phase of the categories of materials that they import. But up to what point? What does this ownership mean for whether the materials are recycled or disposed, whether they go to a right or wrong place in the Netherlands or in the EU or elsewhere?
• In high-income countries, where disposal gate fees are high and automated collection systems are expensive, the revenues from the sale of recycled materials never cover the costs of collecting them. The financial ‘win’ for governments and waste management companies is that well-run high-participation recycling diverts materials from disposal, and so reduces the overall cost of integrated waste management systems.
• But what if, as is currently the case in some EU countries, the quality of packaging waste is so low that producers cannot afford to recycle any material from it, and instead have to pay to send it to an incinerator to recover energy? Can this be called ‘recycling’?

Exporting waste or trading value: diametrically opposed ideas of the meaning of the words ‘waste trade’

• In one Central American country, beverage producers agreed with the government that they would take back “and recycle” all PET bottles. In 2014, one of the panellists visited a PET recycling plant financed and operated by beverage producers, and saw how the bottles were milled into flakes, partially sorted and shipped in big bags, including stones and gravel and other residues. The operator explained that they were shipped like this to a buyer in Asia “because the recycling is cheaper there”. Is this export of recyclables for trading, or of waste for disposal? Should this be called recycling?
• In Europe, many national governments believe that the government owns recycling. And many waste management companies have significant recycling collection and pre-processing operations so that they can meet government requirements. But these companies are not users of recyclables, so sometimes the processed materials cannot be marketed. At the present time, this creates a situation where a large volume of discarded products and waste materials are collected, but then there is no industry within the European Union that wants to pay for them. Is it better to export them to a company that can use them, or to dispose of them closer by?

• In some African countries, imported used vehicles, electronic devices, and parts and components harvested from high-income-country waste streams provide the necessary ‘hardware’ for modernisation of key sectors, such as logistics, mobility, banking, health care and education. The legal availability of imported, high-quality (solid state, repairable) devices and parts is a key element in making these benefits available, and is referred to in countries like Kenya and Ghana as ‘digital solidarity’. In contrast, in the exporting high-income countries the export of used equipment is presented as criminal, discriminatory, dangerous and exploitative, adjectives which make sense to the accusers, but which receiving businesses and their workers – that is, those presented to the international press as ‘victims’ or ‘exploited labour’ – frequently neither recognise nor agree with. In the African tech sector, for example, there is a widespread perception that European countries choose to support their own incinerator industry rather than facilitating circularity and digitalisation through the repair, reuse and refurbishing of second-hand devices and systems. In what cases is export a good idea? Is exporting to Africa legitimate trade or is it a criminal activity? Should the Basel Convention be adjusted to facilitate and control this trade, or to eliminate it?

Export dilemmas: shipping waste for disposal, or transporting recyclables for manufacturing

Movements of waste and recyclables between countries are motivated by two very different drivers – although it is not always possible to tell, looking at the contents of a shipping container, which driver is operating.

For waste materials, the driver is the demand for the service of treatment and disposal. Examples include movements of (hazardous) waste from the country where they are generated to a treatment or disposal facility in another country. The driver for the exporting party is usually capacity or cost. The exporter may not be in a country that has treatment or disposal options in the country of origin that meet requirements and specifications required by law or by the generator, or treatment capacity may not be available, or available capacity in the country of origin may be more expensive than the facilities in the chosen receiving country. The exporter then pays both the costs of export and the legally required gate fee at the facility in the country where the waste is being treated and/or disposed of. The OECD Control System for waste recovery, the EU Waste Shipment Regulation, and the Basel, Stockholm and Rotterdam conventions govern the transboundary movement of wastes for treatment and disposal.

Material and/or component value is the driver for the export of valuable recyclables or reusables for sale to a client in the receiving country. This trade is legal and takes place under a purchase order. A key issue here is that secondary materials prices are highly volatile, so it is important to have a purchase order.

The decision to export recyclables is usually made by the receiving processing facility, on the basis of price offered vs cost of transport. Lower-value and high-specific-density materials, such as glass and secondary construction aggregates, are usually sold close to the point of processing to prevent transport costs exceeding the value of the materials. For example, until recently, processors of beverage packaging in the Americas were sending low-value flaked PET to Asia because the combination of a low price and low shipping costs meant that this was cheaper for them than selling it into the North American or European markets. This trade was and is legal, but the panellists were of varying opinions as to whether it is morally correct. In the event, China’s response to limit the import of low-value plastics in 2018 by lowering the accepted levels of contamination, referred to as the China National Sword, shifted the calculus of legal recycling exports in a fundamental way, and the restriction of low-value importation of recyclables has spread to other formerly importing Asian nations as well. Concern about contamination and politicisation of the issue of waste transport for illegal disposal have created a high level of global outrage.

China’s legal steps to reduce the import of contaminated recyclables is reported to have contributed to a decrease in both legal and illegal transports of waste and recyclables, compared to the last few decades of the 20th century. This is resulting in a discourse – at least in Europe – about the need to stop all exports, even those which are legal, inspected, manifested, under a purchase order and approved by export-import regimes in both exporting and importing countries. This, in combination with the impacts of the blockage of the Suez Canal by the Evergreen in 2021, and the global impacts of COVID on production and shipping and the shortage of shipping containers, has been changing the landscape for transboundary recycling trading in ways that were unthinkable 10 years ago.

The same pressures are affecting the legal transport of waste, but the situation is complicated by the genuine illegality of some waste transport, such as when the exported waste has different levels and concentrations of hazardous components than those that are stated in the manifest. In lower-income countries where environmental legislation is weak or ambiguous, and customs authorities may lack capacity for monitoring and

Recycling close to home, or where the demand is?

Virtually all high-income countries (and a few emerging economies) encourage recycling and stimulate it via laws and targets for two reasons:

1. ‘The push’: service chain motivation: diverting recyclables from paid disposal reduces the tonnes of material that have to be disposed of in landfills, and, for countries that can afford waste-to-energy facilities, is generally a less expensive option than recovering energy, even when energy revenues are factored into the calculation. The higher the recycling rate (usually measured in tonnes diverted), the lower the overall waste system costs.
2. ‘The pull’: value chain demand: recyclables sold to and used by the recycling industry in manufacturing processes reduce some of the extraction and production impacts of making virgin materials available, and therefore contribute to resource efficiency and – according to many calculations – offset CO2 impacts of extraction and production.

Interestingly, benefits associated with both the push and the pull are only available if and when the recyclables are used for economically important activities. No matter where the motivation lies, recycling depends on the demand from industrial markets. High-income countries are high consumers of products and materials but not necessarily the producers of the products, and this can create an imbalance in materials movements. In North America, when cities and counties were introducing weight-based targets in the early 1980s, the paper and metals industries protested that they could not use so many materials coming out of municipal solid waste. But as more and more cities started delivering cleaner recyclables – also when the prices were low – the industries gained confidence and demand gradually expanded, although always with significant levels of (legal) export. In the 1990s, the largest exports from the Port of New York and New Jersey were scrap metal and waste paper being sold by recycling traders in the Northeastern USA to recycling industries in Japan. Despite this decentralised activity, the US has no national weight-based targets at the time of writing, and diversion levels have stabilised at approximately 34% by weight of municipal solid waste for the last decade.

The acceptance of public bodies that the benefits of municipal recycling were dependent on public sector suppliers learning to meet high-quality specifications of end-user manufacturers was facilitated both by public sector entities at the state level, including New Jersey, Massachusetts and Rhode Island, at multi-state level in the Northeast and Western states, and at County level, with King County (Washington State), Tompkins County (New York) and Boulder County (Colorado). This was soon followed by the larger cities such as New York, Portland (Oregon) and San Francisco.

Similarly, in the European Union, weight-based recycling targets currently serve as operational drivers for recycling at the level of cities and regions, and also for the private waste industry. Export under purchase order has been a key contributor to the ability of many EU countries to be able to market their recyclables via export within the EU, to non-EU countries and to Eurasia (stretching from Turkey to Japan). The success of EU waste policy, and especially the ability to declare some materials ‘end of waste’, has depended on the ability of governments or EPR stakeholders to move materials to industrial users. As more and more materials enter the recycling stream, this puts pressure on industrial recycling value chains to maximise the volumes of discarded products that they accept for material recycling. When the ‘proximity principle’ is applied, the relation to the recycling value chains begins to look more and more like a service relationship, especially when countries with small or limited heavy industry seek markets for materials within their own borders. When there are no domestic buyers, and when the waste trade becomes criminalised, these recyclables are pushed to energy recovery as the next best solution.

Together with waste trade criminalisation, EU recycling targets may have – directly or indirectly – contributed significantly to the local shredding and recycling of materials from electronic and electric devices and from equipment and vehicles that could otherwise still have been reused (entirely or in the form of spare parts) in lower-income countries, contributing to a global circular economy.

Should we pay attention to the difference between criminalising trade and promoting something that deserves to be legal according to global consensus?

Drivers and dilemmas: contributions from the panel as the basis for the WGRWM 2022-2023 work program

As the Working Group on Recycling and Waste Minimisation, we will be using this session as the basis for our 2022-2023 work programme, also in the context of the ISWA Scientific and Technical Committee’s new work streams. We will be working with our members on three initiatives:

1. Drivers for recycling in cities and regions in our emerging economy member countries. We have decided to conduct a global network query and survey to look at the relationship between disposal gate fees and recycling rates (the financial driver). In these countries, the hypothesis is that informal recycling is most of the recycling until gate fees are introduced. And that once they are introduced, the higher the gate fee, in combination with the extent to which all waste transported to the disposal facility is subject to this gate fee, the higher the formal recycling rate. We are also interested in how policies to integrate or formalise the informal recycling sector contribute to the recycling rate. Our hypothesis (to be refined) is that the price of disposal is a more important driver than direct weight-based targets, but this is really an open question. The WGRWM will be sending a survey to its members and others. If you would like to participate, please send an email to Dienke Dijksterhuis at ddijksterhuis@iswa.org.
2. Where are recyclables going: understanding the global trade in recyclables and developing strategies to improve its socio-economic and environmental footprint. How much of a problem is the export of recyclables? The Basel Convention is putting more and more controls on trading recyclables: what are the impacts on recycling rates and movements of recyclables? There has been a lot of work done by ISWA on plastics, but not much on the global trading of core traditional recyclables, ferrous and non-ferrous metal, paper and cardboard, and glass. This is a work stream to be developed together with the Scientific and Technical Committee.
3. What approach works best to maximise positive climate impacts of recycling: the circular economy; zero waste ; or resource efficiency. Researchers, scholars, policymakers and statisticians are among many stakeholders working on assessing which of these three approaches -- or some combination of them -- can best contribute to achieving global goals for reducing greenhouse gas emissions? three global streams – above all a source of debate in high-income countries – are all advocating for more recycling on the one hand, and and repair, re-use and recovery (moving ‘up the hierarchy’) on the other. What are they doing about waste prevention? And is there evidence as to which approach works better under which circumstances?

By Dirk Nelen, Dr Anne Scheinberg and Max Narinx, with contributions from ISWA WGRWM members Michael Simpson, Peter Hodaček, Joachim Quoden, Jeff Cooper and Dr Henning Friege