Plastics recyclers and up-stream waste management companies are experiencing a shifting landscape in waste classification, bringing with it a number of challenges. These include assigning the correct waste codes, identifying and managing POPs (Persistent organic pollutants) wastes, and adapting to changes in the classification of substances such as lead and copper. Last week I had the pleasure of talking on this subject at the British Plastics Federation’s recycling seminar.
Historically, there has been a heavy reliance on the use of non-hazardous waste codes to move and process plastic-rich wastes. In recent years the use of these codes has been questioned more often by the regulator, resulting in a requirement for evidence to demonstrate non-hazardous status. The industry has taken on board the need for more comprehensive testing to support waste classification, but it is a complex arena. Waste classification methods are laid out in regulatory guidance WM3, but even with this guidance there are pit falls for multi-component waste streams.
Producing representative samples of waste streams that may be generated at hundreds of thousands of tonnes a year, and preparing these so they are suitable for laboratory analysis is not straight forward. Waste must be sampled over time to provide a sample that is representative, and then sub-sampled to produce a large sample for laboratory preparation to avoid introducing sample bias. The samples must be size reduced without impacting their chemical nature, to provide the laboratory with a sample that will yield meaningful data on the true composition of the waste.
The laboratory will then take a very small amount of this sample typically less than 1 g, for extraction and digestion before a final quantification step using highly sophisticated analytical equipment. In many cases the analytical methods used by the test facilities were largely validated on environmental substances (e.g. water, air and dust) rather than plastic-rich wastes with complicated matrices, and laboratory accreditation is based on similar tests. Careful evaluation and a critical eye is needed to ensure reported compositions are realistic of what you are trying to test.
Some plastic waste, such as casings from electronics, contain persistent organic pollutants (POPs). These are substances that bioaccumulate and do not break down naturally, so their concentrations in the environment are increasing. Some substances now considered POPs were manufactured in large volumes and legitimately added to products to provide functionality, such as flame retardancy in plastics and textiles. Their use was later restricted or banned when long-term impacts were identified resulting in legacy issues for recovery and treatment of the wastes of today.
As a result, there is a legal obligation in the UK to isolate and destroy waste that contains POPs above a prescribed threshold. This has led certain recyclers, such as those treating Waste Electrical and Electronic Equipment (WEEE), to make significant changes to their process to meet this obligation.
Recyclers treating POPs-containing WEEE plastics have invested in infrastructure to prevent unintended release of POPs and have to ensure their POPs-containing waste is incinerated. The outlets for such POPs waste are limited, and since landfill is not an option it adds a level of risk and uncertainty to the recycling operation.
There are more problems on the horizon. The list of POPs will increase as more substances are evaluated and indeed this includes the chemical alternatives to initial POPs chemicals and the concentration thresholds at which a waste is considered a POPs waste will also reduce. This will likely result in more waste being classified as POPs, requiring special processing and disposal, adding to the competition for a finite appropriate offtake capacity.
It is also possible the UK may follow the EU in restricting the concentration of lead in new products which could have a knock-on effect for PVC recycling, where lead has historically been used as a stabiliser. A restriction on lead in new products may limit the uptake of recyclate. Although the UK has not implemented such a restriction yet, it may already have an impact on the sale of recyclate and products into the EU.
In addition to all of this, fine copper particles, such as small copper wire, have been classified as ecotoxic. Many polymer rich streams from sources such as waste electricals and automotive shredder residue are likely to contain this type of copper, and therefore are at risk of potentially being classified as hazardous due to ecotoxicity.
It is apparent there are several regulatory challenges for recyclers of non-packaging plastics, and with low polymer prices, and high energy and labour costs it is a difficult time. Ensuring you stay up to date with any changes is key, and carrying out representative and accurate waste classification will help ensure you remain compliant.
This is a complex space and at WRc we are experienced in guiding brands and retailers through the intricacies of waste characterisation. Get in touch if you would like to discuss how we can help you.