The challenges towards a circular economy for WEEE plastics –

European consumers are ready to take up more recycled plastics from WEEE.  Capacities and innovations of this complex and new recycling industry for WEEE plastics need to be stimulated by a clearer, simpler, and more stable legal framework based on the ‘one substance – one assessment’ approach. Unworkable substance thresholds should be avoided to guarantee compliance.

Chris Slijkhuis is the former General Manager of MGG Polymers, a specialised WEEE plastics recycling company.

Today over 3 million Metric Tons of valuable tech-plastic are used in new electronics.  Recycling these plastics makes a lot of sense from an environmental point of view, as the energy for the extraction, refining and polymerisation and kept in these recycled polymer chains, thus resulting in enormous CO2 and energy savings compared to the production of virgin tech plastics.

Today, too small the quantity of WEEE plastics is currently truly circular, and this needs to be increased. With potential CO2 emission savings of some 6 million metric tons, if only half of these plastics are recycled, the environmental benefit of proper recycling is enormous.  The energy savings are in the order of 90 % compared to the production of virgin tech plastics.

Today closed circular applications are available where plastics from WEEE (Waste of Electric and Electronic Products) are converted to new technical plastics that are re-used in high-tech electronic products.

It can be done, and specialised and highly technical recyclers – a new industry – do a remarkable job also managing legacy substances such as some restricted brominated flame retardants.  Unfortunately, several impediments need to be addressed.

One key element is that around half of all WEEE plastics generated in Europe do not enter official WEEE collection channels, where one may expect that these plastics end up being processed at substandard treatment processes or are being (illegally) exported outside the EU.

Of the total amount of WEEE plastics entering the waste stream, less than a quarter ends up in specialised recycling facilities, capable of recycling these plastics for accurate circular applications.  One reason has been that the logistics of the movement of these approximately 1 million tons of WEEE plastics to specialised recycling facilities within the EU are facing long delays.

This is caused by waste not enjoying the freedom of movement that people, products, and money have in the EU.  For a long time, the approvals for the shipment of these WEEE plastics have taken far too much time, which is unacceptable for the high-tech industry that requires plannability.  The current review of the EU Waste Shipment Regulation will hopefully result in much faster administrative procedures, and the recycling industry is eagerly awaiting these so-called “fast-track notifications”, at least within Europe.

These specialised WEEE plastic recycling facilities sort the plastics by a series of cleaning and separation steps into small pieces of plastics called flakes that are being analysed on the compliance with existing EU chemicals legislations.  Unfortunately, the recycling industry faces more than one set of rules and standards.

Not only is there the EU chemicals legislation REACH, which was introduced in 2007 with the promise that it would replace all other chemical regulations and directives.  Today, the recycling industry is still facing several – sometimes conflicting – chemical legislations and standards.  The recycling industry is faced with the REACH and POP regulations and the RoHS directive, and many additional industry standards.

The industry has been calling for simplification and was happy about the promise of the European Green Deal to review how to move towards a process of ‘one substance – one assessment’ to provide greater transparency.  Why this is important is shown by a current discussion about a group of substances known by the abbreviation PBDE, which is being assessed by the Stockholm Convention, the Basel Convention, the REACH and POP regulations, and the RoHS Directive regularly, with differing assessments, approaches, and thresholds.  The EU POP Regulation, which changed the thresholds for recycled materials as recently as June 2019, is proposing further reductions.

The recycling industry is facing continuously changing – in practice lowering – thresholds of a substance group that, in essence, is a legacy substance.  Electronics are products with a long lifetime, and the recycling industry has to make sure to separate any materials containing restricted substances.

The technologies, analyses and screening methods are present to do this, but it is impossible to work with thresholds that are so low that they cannot realistically be met or screened to prove legal compliance.   These reductions in the POP Regulation, well below those of REACH and RoHS, if materialised, certainly will stop innovations in this new industry sector and might even result in the closure of some recycling facilities.

To most effectively increase the circularity of WEEE plastics is to improve the collection rate of WEEE and to ensure that a proper recycling process is taking place in the EU.  This is where the WEEE directive, the Waste Shipment Regulation and the European Chemicals regulations intersect.

To increase the quantity of plastics recovered from WEEE, innovations to recover other polymers are needed.  This can only be achieved by additional resources (time, know-how, capital) to optimise the design of new electric and electronic products to increase the recyclability and optimise the take-up of recycled plastic from WEEE.   Such innovation processes typically take 5 years or more.  Circularity calls for a stable legal framework with regular and consistent legal thresholds.

Increasing the collection rate and developing new and innovative techniques to recycle more and other polymers from the WEEE plastics are the best solutions for a more sustainable WEEE plastic management.   The review of the WEEE directive offers opportunities.

Recyclers are faced with complexity and administrative burdens when moving recyclable materials across borders.  The current Waste Shipment regulation review offers tools to simplify this complexity.

With the principle of continuity of keeping material in circulation, one substance should have one assessment for the setting of legal thresholds, and there needs to be more stability in the chemical legislation.

This is where there is a lot of room for improvement.

The Circular Economy calls for more WEEE plastic capacities and for more innovation, which will save large quantities of energy, resources, and CO2 emissions.

A clever combination of the review of the WEEE directive, the Waste Shipment Regulation and a “One-Substance – One Assessment” approach can make this work.  The Circular Economy needs this clever combination of legal frameworks, which are both consistent and workable by recyclers.


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