support to the waste targets review...member state report includes the following sections: section...
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SUPPORT TO THE WASTE TARGETS REVIEW
FINAL REPORT
Dr Dominic Hogg
Thomas Vergunst
Timothy Elliott
Laurence Elliott
Mark Corbin
Hulda Norstein
22nd July 2016
Report for: DG Environment of the European Commission
Prepared by: Thomas Vergunst, Timothy Elliott, Laurence Elliott, Mark Corbin, and Hulda Norstein
Approved by
Dominic Hogg
(Project Director)
Eunomia Research & Consulting Ltd 37 Queen Square Bristol BS1 4QS
United Kingdom
Tel: +44 (0)117 9172250 Fax: +44 (0)8717 142942
Web: www.eunomia.co.uk
Disclaimer
Eunomia Research & Consulting has taken due care in the preparation of this report to ensure that all facts and analysis presented are as accurate as possible within the scope of the project. However, no guarantee is provided in respect of the information presented, and Eunomia Research & Consulting is not responsible for decisions or actions taken on the basis of the content of this report.
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Contents
1.0 Introduction ................................................................................................... 1
2.0 Analysis of New Policy Options ....................................................................... 3
3.0 Member State Summary Reports .................................................................... 4
4.0 Municipal Waste Definitions and Review of Generation Data .......................... 5
4.1 Introduction ............................................................................................................ 5
4.2 Member State Consultation .................................................................................... 6
4.3 Approach to Analysis .............................................................................................. 7
4.4 Limitations of Analysis .......................................................................................... 11
4.5 Household Waste .................................................................................................. 12
4.5.1 Definition ........................................................................................................ 12
4.5.2 Comparison with Municipal Waste ................................................................ 13
4.6 All Household and Similar Wastes ........................................................................ 16
4.6.1 Definition ........................................................................................................ 16
4.6.2 Comparison with MSW Reported ................................................................... 20
4.7 Household and Similar Wastes Collected by or on Behalf of Municipalities ........ 22
4.7.1 Definition ........................................................................................................ 22
4.7.2 Comparison with Municipal Waste ................................................................ 24
4.8 Comparison of Definitions .................................................................................... 26
4.9 Conclusions ........................................................................................................... 30
5.0 Measuring Recycling Performance ................................................................. 32
5.1 Legislative Background ......................................................................................... 33
5.2 Member State Consultation .................................................................................. 36
5.3 Tracking Waste Materials ..................................................................................... 39
5.3.1 Challenges Associated with Quantifying Waste Flows .................................. 39
5.3.2 Options for Tracking Waste Flows ................................................................. 43
5.4 Quantifying Material Losses ................................................................................. 46
5.5 Industry Specifications on Material Quality ......................................................... 53
5.6 Outlining an Approach to Measuring Recycling ................................................... 54
5.6.1 Measurement Point ........................................................................................ 55
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5.6.2 Final Recycling Process ................................................................................... 58
5.6.3 Material Losses ............................................................................................... 58
5.6.4 Summary ........................................................................................................ 61
6.0 Reuse Targets ................................................................................................ 64
6.1 Background ........................................................................................................... 64
6.2 Member State Consultation .................................................................................. 70
6.3 Data on Reuse ....................................................................................................... 71
6.3.1 Packaging Waste ............................................................................................ 71
6.3.2 Municipal Waste ............................................................................................ 75
6.3.3 Administrative Burden of Gathering Data on Reuse ...................................... 79
6.4 Assessing the Impact of a Combined Reuse Target .............................................. 83
6.4.1 Packaging Waste ............................................................................................ 83
6.4.2 Municipal Waste ............................................................................................ 98
7.0 Material Recovery from MBT and Incineration Facilities............................... 102
7.1 Rates of Material Recovery ................................................................................. 102
7.1.1 Metal Recovery from Incinerators ................................................................ 102
7.1.2 Metal Recovery from MBT Plants ................................................................. 104
7.1.3 Extraction of Other Materials ....................................................................... 105
7.2 Material Quality .................................................................................................. 107
7.2.1 Metals Recovered from Incinerators ............................................................ 107
7.2.2 Materials Recovered from MBT Facilities .................................................... 110
7.3 Reporting Against Recycling Targets ................................................................... 115
7.3.1 Metals Recovered from Incinerators ............................................................ 115
7.3.2 Materials Recovered from MBT Facilities .................................................... 119
8.0 Other Contractual Deliverables .................................................................... 126
8.1 Additional Analysis and Technical Support ......................................................... 126
8.2 Dissemination of the Result ................................................................................ 126
8.3 User Guidance and Technical Documentation ................................................... 127
8.4 Training and Helpdesk Support ........................................................................... 127
8.5 European Reference Model on Municipal Waste Management ........................ 128
Appendices .............................................................................................................. 129
A.1.0 Analysis of New Policy Options ....................................................................... 129
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A.2.0 Country Summary Reports .............................................................................. 129
A.3.0 Understanding Material Losses ....................................................................... 129
A.4.0 Industry Quality Specifications for Secondary Materials ................................ 129
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1.0 Introduction
After the withdrawal of the legislative proposal under the previous circular economy package the European Commission published a revised version of the package in December 2015.1 Eunomia Research & Consulting (Eunomia) and colleagues assisted DG Environment of the European Commission with the first revision of the waste management targets in 2013 and 2014.2 Under this follow on contract, Eunomia was commissioned by DG Environment to provide additional technical support to the Commission on issues related to the new legislative proposal which forms part of the revised package, and the further development and enhancement of the European Reference Model on Municipal Waste Management.
The project brought together a number of strands of work, which are presented in the following sections of this report:
Section 2.0 – links directly to Appendix A.1.0, which is a self-contained report presenting a detailed analysis and discussion of the policy options which have been included in the Commission’s supplement to the impact assessment on the revision of European waste management targets.3 A total of 19 different scenarios – each made up of varying combinations of one or more waste management targets – were modelled, and the results compared to provide a clear picture of how various policy packages and targets perform relative to a counterfactual scenario. The results of this work fed directly into the Commission’s supplement to the impact assessment.
Section 3.0 – Member State summary reports have been developed which present the results from the cost benefit analysis in a systematic way, in order to show how the final costs and benefits were derived for the Commission’s chosen policy scenario.4 In order to facilitate easy dissemination, these reports have been prepared as separate documents under Appendix A.2.0.
1 European Commission (2015) Circular Economy Strategy, Date Accessed: 8th March 2016, Available at: http://ec.europa.eu/environment/circular-economy/index_en.htm 2 Eunomia Research & Consulting, Copenhagen Resource Institute, and Öko-Institut (2014) Impact Assessment on Options Reviewing Targets in the Waste Framework Directive, Landfill Directive and Packaging and Packaging Waste Directive, February 2014, http://ec.europa.eu/environment/waste/pdf/target_review/Targets%20Review%20final%20report.pdf 3 European Commission (2015) Commission Staff Working Document: Additional Analysis to Complement the Impact Assessment SWD (2014) 208 Supporting the Review of EU Waste Management Targets, December 2015, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52015SC0259&from=EN 4 The Commission’s chosen scenario corresponds to Option 3.9(c). This scenario assumes that Member States will use their chosen method for the existing 2020 target. It then sets an interim recycling/preparation for reuse target of 55% in 2025, increasing to 65% in 2030. The 2025 and 2030 targets in this scenario are calculated using Method 4 for all Member States (i.e. % total municipal solid waste recycled/prepared for reuse).
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Section 4.0 – presents an analysis of how, for individual Member States, different definitions of municipal waste change the reported amount of municipal waste generated. This section also aims to provide an example of how the definition of municipal waste used by Eurostat / OECD might be linked to the European Waste Statistics Regulation as a means of providing a clearer definition that could allow for greater harmonisation in reporting across Member States. This section was developed prior to the publication of the Commission’s package in December 2015, and therefore does not include an analysis of the proposed definition for municipal waste.
Section 5.0 – examines how Member States could measure performance against the proposed recycling targets in a consistent manner. As part of the 2014 waste legislative proposal the Commission put forward a proposal that all material losses greater than 2% would have to be accounted for by Member States when reporting on municipal and packaging recycling targets. This section was mostly developed prior to the publication of the revised package and was intended to provide some suggestions of how the measurement method could be structured, while taking into account initial reactions to the Commission proposal presented in December 2015 in its conclusions.
Section 6.0 – introduces the concept of reuse and differentiates it from preparation for reuse. A discussion is provided regarding how a reuse target could be set and what the impact might be of allowing reuse to count towards the existing preparation for reuse / recycling targets in the Waste Framework Directive and Packaging and Packaging Waste Directive.
Section 7.0 – based on a detailed literature review and data contained in the European Reference Model on Municipal Waste Management, this section quantifies what volume of material could potentially be recovered from Mechanical Biological Treatment (MBT) and incineration facilities, and what impacts this has, or, in the case of metal recovery from incinerators, may have, on Member States’ recycling rates.
Section 8.0 – provides an overview of how Eunomia has met the remaining requirements set out in the Terms of Reference for the project.
The European Commission consulted Member States directly via means of a questionnaire on the circular economy between July and September 2015. A number of questions included in this consultation related directly to the topics covered in Sections 4.0, 5.0, and 6.0. These Sections, therefore, each include a summary of the results of the consultation, which helps to distil the key messages and concerns of the 20 Member States that provided written responses.
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2.0 Analysis of New Policy Options
A key element of the work undertaken as part of this contract was to revisit the analysis undertaken for the Commission’s supplement to the impact assessment on the revision of the European waste management targets.5 In addition, the Commission wanted to consider a number of new policy options. This work was presented as a separate report and is included under Appendix A.1.0.
By way of overview, Appendix A.1.0 includes the following sections:
Section 1.0 – provides an introduction to the report.
Section 2.0 – describes how the European Reference Model on Municipal Waste Management (the Municipal Waste Model) and earlier versions of Eunomia’s Packaging Waste Model and Landfill Diversion Model have been updated to allow for the costs and benefits of a revised suite of policy options to be assessed.
Section 3.0 – provides a summary of the 19 policy options analysed as part of this contract.
Section 4.0 – presents the EU28 results for the key policy scenarios that have been included in the Commission’s supplement to the impact assessment.
Section 5.0 – compares the overall results of the 19 policy scenarios modelled and looks at the synergies between different policy packages.
Section 7.0 – discusses the key model sensitivities by examining how changes in input assumptions impact the final model outputs.
Interested readers should refer to Appendix A.1.0 for further details on the European Reference Model on Municipal Waste Management and the suite of policy options included in the Commission’s supplement.
5 European Commission (2015) Commission Staff Working Document: Additional Analysis to Complement the Impact Assessment SWD (2014) 208 Supporting the Review of EU Waste Management Targets, December 2015, http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52015SC0259&from=EN
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3.0 Member State Summary Reports
In order to facilitate the easy dissemination of the results and to allow for better understanding of how the model outputs were derived, Member State summary reports have been prepared based on the outputs of the analysis reported in Appendix A.1.0. These summary reports present the results for the cost benefit analysis to show how the final costs and benefits were derived for the Commission’s chosen scenario (i.e. Option 3.9(c)). These reports provide a good basis for understanding the outputs of the technical modelling and how the results were built up based on country specific data provided during the development of the Municipal Waste Model.
Individual reports and data tables have been created for each Member State to allow for easy dissemination, and these are saved in a standalone folder under Appendix A.2.0. Each Member State report includes the following sections:
Section 1.0 – introduces the summary report.
Section 2.0 – explains the process behind how the Municipal Waste Model was developed with direct input from Member States. The section cross references to Appendix 1, which also outlines the key changes that have been made to the model.
Section 3.0 – given the complex nature of collections modelling, and the interest shown in this area of the model since the publication of the results of the impact assessment, this section provides a broad overview of how the model accounts for the collection of municipal solid waste.
Section 4.0 – this section sets out the main uncertainties associated with the Municipal Waste Model, which are important to bear in mind when considering the results presented in the Member State summary reports.
Section 5.0 – this section introduces the Member State Data Tables which accompany each summary report, and which are intended to provide a repository of key assumptions and data relating to the analysis undertaken as part of this contract.
Section 6.0 – this section provides an outline of some of the specific information and data that has been used to assess the costs and benefits of each Member State moving towards achieving the Commission’s chosen scenario by 2030 (or 2035 for countries with a time extension).
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4.0 Municipal Waste Definitions and Review
of Generation Data
4.1 Introduction
As required by the Terms of Reference for the project, the work presented in this Section was undertaken prior to the publication of the revised legislative proposal in December 2015. The analysis presented below, therefore, does not explicitly consider the exact phrasing of the new definition of municipal waste put forward by the Commission in the revised text for Directive 2008/98/EC. However, the details presented here provide a useful indication of how the quantity of municipal waste may vary under different definitions of the term.
Eunomia et al’s work on the revision of the waste targets outlined a number of issues associated with the current definition of municipal waste and explained why the current definition is ambiguous and leading to significant inconsistencies in Member State reporting.6 It was our view that underpinning any target, there should be a consistent means of measurement and verification. The potential for improving the reporting on any waste fraction ideally starts from a clear definition about what it is that should be reported upon.
The current definition of municipal waste, which is intended to be used in reporting municipal waste data, is somewhat lengthy, and appears to have been extended over time rather than being streamlined. Notwithstanding attempts to clarify a definition, Member States appear to have continued to report on municipal waste arisings in a variety of ways, which makes cross comparison between countries more challenging.
Given the varying interpretations of municipal waste, there is some value in trying to understand what volume of municipal waste would be generated by Member States if they all adopted the same definition. This Section seeks to do this using the following restrictions on the definition of municipal waste:
If only household waste (waste generated by households) is considered;
If all waste similar in nature and composition to household waste is included; and
If only waste collected by, or on behalf of, municipalities is included.
Each potential definition is assessed in turn, setting out:
How these definitions are best mapped onto existing data reported to Eurostat under the Waste Statistics Regulation (WStatR) 7 and/or municipal waste data; and
The corresponding level of municipal waste that would be reported were this definition (and corresponding mapping) in use.
6 Eunomia Research & Consulting, Copenhagen Resource Institute, and Öko-Institut (2014) Impact Assessment on Options Reviewing Targets in the Waste Framework Directive, Landfill Directive and Packaging and Packaging Waste Directive, February 2014, http://ec.europa.eu/environment/waste/pdf/target_review/Targets%20Review%20final%20report.pdf 7 Regulation (EC) No. 2150/2002, amended by Commission Regulation (EU) No. 849/2010
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The impact that each of these definitions would have on the total amount of municipal waste generated was analysed using 2012 Eurostat data for each of the 28 Member States (this was the most recent year for which data were available at the time the analysis was undertaken).
This Section includes the following sub-sections:
Section 4.2 – summarises the feedback from Member States received as part of the Commission’s consultation on the circular economy, which was held over the summer of 2015;
Section 4.3 – outlines the approach to the analysis and the key assumptions that have been made;
Section 4.4 – provides a brief overview of the key limitations that need to be born in mind when interpreting the results which have been generated using Eurostat data;
Section 4.5 – examines what municipal waste arisings would be if only certain elements of household waste reported under WStatR was considered as part of the definition;
Section 4.6 – defines what may be included in the definition of ‘all household and similar waste’ by linking the definition to the WStatR categories. This allows for the calculation of what such a definition may look like if applied consistently across all Member States (this is obviously based on the assumption that the reporting to Eurostat on the different categories has been undertaken on a consistent basis – this level of interrogation was beyond the scope of this study);
Section 4.7 – examines likely arisings of municipal waste if it were to be defined as waste collected by or on behalf of municipalities; and
Section 4.8 – provides an overview by comparing the estimated arisings based on each of the definitions listed above, and by comparing them to current levels of municipal waste reported to Eurostat.
4.2 Member State Consultation
Member States were consulted directly by means of a short questionnaire issued by the European Commission in July 2015. A total of 20 Member States responded to the consultation. This questionnaire included the following four questions in relation to the definition of municipal waste:
1) “Should the definition remain neutral as to who is responsible for collection/management of the targeted waste stream (e.g. municipalities or private actors)?
2) To what extent should the definition include waste from retail, trade, small businesses, office buildings and institutions that is similar in nature and composition to household waste? Would a quantitative criterion be useful?
3) Is there a need to establish a clearer link between the OECD/Eurostat definition and the list of waste codes as specified in Commission Regulation (EU) 849/2010?
4) Do you have any additional technical suggestions to improve the definition proposed by the Commission in 2014?”
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All of the Member States that responded to the consultation stated that they felt that the definition of municipal waste should remain neutral with regards to who is responsible for its collection. A large majority of Member State respondents also supported the notion that the definition of municipal waste should extend beyond household waste and include “waste from retail, trade, small businesses, office buildings and institutions that is similar in nature and composition to household waste” though two member states stated they would like to see the definition restricted to wastes which municipalities actually collect. Likewise, there was strong support for linking the definition of municipal waste to clearly defined waste codes, with 13 Member States broadly in favour and three opposed.
One Member State stated that municipal waste should only include household waste, whilst another was of the opinion that there is no need for harmonisation and that Member States should, therefore, be allowed to define municipal waste in the manner which best suited their national circumstances. The first of these positions would still allow for comparison across countries, but the second would not, and would allow the existing inconsistencies to remain. The first would require some countries – especially those currently collecting waste using road containers / bring schemes – to estimate the proportion of waste being collected that was not from households.
4.3 Approach to Analysis
As discussed above, the scope of waste currently reported as municipal waste varies from one Member State to another, but is likely to sit, for each country, at some point on a spectrum of values between the amount of household waste generated and the amount of all household and all similar waste.
As part of Eunomia et al’s earlier work on developing the European Reference Model on Municipal Waste Management, information on the definition of municipal waste was gathered for each Member State.8 In broad terms, half of Member States stated that they report municipal waste as waste collected by or on behalf of municipalities, whereas half report on household and similar wastes, irrespective of who collects it.
Harmonised reporting around any single definition poses challenges for Member States due to the reality – and variety – of collection systems and corresponding opportunities to collect accurate data. The variations within wastes reported as MSW are down to, for instance:
What is actually collected by or on behalf of municipalities, and the challenge of distinguishing household waste from trade waste, especially where commercial waste is not collected separately from household waste but collected alongside it, either at bring sites or in the same collection vehicles.
Recycling collection systems and data: in bring-site-based recycling collection systems, recycling from households is not necessarily distinguished from other trade
8 See Appendix 1 in Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission Directorate-General for the Environment, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip
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and industry waste; additionally, as the List of Waste does not include packaging within Chapter 20 (entitled ‘municipal waste’). Latvia and Estonia (and potentially others) were, in 2012, reporting municipal waste as excluding separately collected packaging waste.9
Individual variation in the scope of reporting: Ireland and Finland, for example, include an estimate of home-composted waste within their municipal waste data.
The above issues make it very challenging to compare the rates of municipal waste generation in different countries (e.g. as kg per inhabitant). However, in addition to the data on municipal waste that Member States report, the Waste Statistics Regulation requires Member States to report quantities of waste generated in a different format. These reported data are broken down by both:
waste categories (substance-orientated), broken down into further sub-categories according to the European Waste Classification EWC-Stat; 10 and
source, categorised according to NACE rev. 2.11
The full reporting breakdown (into EWC-Stat categories) is displayed in Table 4-1.
Table 4-1: ECW-Stat Waste Categories Reported under the Waste Statistics Regulations
ECW-Stat Waste Types
W01-05 - Chemical and medical wastes (subtotal)
W011 - Spent solvents
W012 - Acid, alkaline or saline wastes
W013 - Used oils
W02A - Chemical wastes
W032 - Industrial effluent sludges
W033 - Sludges and liquid wastes from waste treatment
W05 - Health care and biological wastes
W06_07A - Recyclable wastes (subtotal, W06+W07 except W077)
W061 - Metal wastes, ferrous
W062 - Metal wastes, non-ferrous
W063 - Metal wastes, mixed ferrous and non-ferrous
W071 - Glass wastes
W072 - Paper and cardboard wastes
W073 - Rubber wastes
W074 - Plastic wastes
W075 - Wood wastes
W076 - Textile wastes
W077_08 - Equipment (subtotal, W077+W08A+W081+W0841)
9 This situation may have changed in more recent reporting. 10 European Waste Classification for Statistics, version 4; available from http://ec.europa.eu/eurostat/ramon/other_documents/ewc_stat_4/index.cfm?TargetUrl=DSP_EWC_STAT_4 11 Statistical Classification of Economic Activities in the European Community, Rev. 2 (2008), available from http://ec.europa.eu/eurostat/ramon/nomenclatures/index.cfm?TargetUrl=LST_NOM_DTL&StrNom=NACE_REV2&StrLanguageCode=EN&IntPcKey=&StrLayoutCode=HIERARCHIC
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ECW-Stat Waste Types
W077 - Waste containing PCB
W08A - Discarded equipment (except discarded vehicles and batteries and accumulators waste) (W08 except W081, W0841)
W081 - Discarded vehicles
W0841 - Batteries and accumulators wastes
W09 - Animal and vegetal wastes (subtotal, W091+W092+W093)
W091 - Animal and mixed food waste
W092 - Vegetal wastes
W093 - Animal faeces, urine and manure
W10 - Mixed ordinary wastes (subtotal, W101+W102+W103)
W101 - Household and similar wastes
W102 - Mixed and undifferentiated materials
W103 - Sorting residues
W11 - Common sludges
W12-13 - Mineral and solidified wastes (subtotal)
W121 - Mineral waste from construction and demolition
W12B - Other mineral wastes (W122+W123+W125)
W124 - Combustion wastes
W126 - Soils
W127 - Dredging spoils
W128_13 - Mineral wastes from waste treatment and stabilised wastes
W06 - Metallic wastes (W061+W062+W063)
W091_092 - Animal and mixed food waste; vegetal wastes (W091+W092)
W12_X_127NH - Mineral waste (except non-hazardous dredging spoils, valid up to 2008)
W12A - Mineral wastes (except combustion wastes, contaminated soils and polluted dredging spoils) (W121+122+W123+W125+W126, valid up to 2008)
W126_127 - Soils and dredging spoils (W126+W127, valid up to 2008)
W13 - Solidified, stabilised or vitrified wastes (valid up to 2008)
TOT_X_MIN - Waste excluding major mineral wastes
Many of these codes contain municipal wastes. Whilst ‘Household and similar wastes’ is evidently part of municipal waste, municipal waste may also be reported within the following codes:
W102 ‘Mixed and undifferentiated materials’;
W06-07a ‘Recyclable wastes’ (broken down into different materials);
W09 ‘Animal and Vegetal Wastes’, and in particular, the sub-categories o W091 - ‘Animal and mixed food wastes’; and o W092 - ‘Vegetal wastes’.
As might be suspected from the list above, similar issues of variability exist within the WStatR data as within the municipal waste data. The amount of waste reported as ‘Mixed and undifferentiated materials’ versus that reported as ‘Household and similar wastes’, for instance, may depend both on the waste collection systems in operation and judgement as to when mixed and undifferentiated wastes are sufficiently ‘similar’ to household waste in nature. Member States are similarly likely to use differing interpretations of the categories, and go to varying levels of effort and accuracy in deriving calculations to apportion co-
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collected waste (e.g. household and non-household wastes) between different types and sectors. This variation is evident within the data: for instance, in 2012 Greece reported no ‘Recyclable waste’ from households, and Denmark reported no ‘Household or similar wastes’ from the services sector.
However, the WStatR data does present an alternative, granular and more standardised data-set from which to build up and compare waste arisings under different definitions of municipal waste.
It may be preferable to define ‘household waste’ with reference to the List of Wastes (LoW). However, data reported is not broken down by specific LoW categories, and though the WStatR classification is linked to the administrative classification used in the List of Wastes (LoW), there is no direct correspondence between the EWC-Stat and high-level categories within the LoW.
Therefore, this analysis is limited, as it is not based on any ideal LoW-based definition, but on an approximate mapping of such a definition onto the available WStatR data. Since the WStatR data is also divided by source (at least to the level of high-level NACE divisions), it provides a reasonable level of granularity for this analysis.
Each of the sub-sections below examines the different definitions for MSW in two parts:
First, a description is provided of what waste streams are assumed to be included in / excluded from the definition being considered, along with the corresponding approximate mapping to WStatR waste categories and sources.
Second, based on this definition, the corresponding amount of municipal waste generated is calculated from the available statistics. These arisings are then compared against the current levels of MSW reported to Eurostat by countries reporting municipal waste data.12 The analysis presented here uses the 2012 data reported by Member States to Eurostat (this was the most recent waste generation data at the time of writing), as displayed below in Figure 4-1.
12 Eurostat (2012), Dataset env_wasmun; available from http://ec.europa.eu/eurostat/data/database
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Figure 4-1: Total MSW Generated Reported to Eurostat (2012, thousand tonnes)
Source: Eurostat, dataset env_wasmun
4.4 Limitations of Analysis
As noted above, the data reported under WStatR may be subject to variation between Member States, both in terms of definitions and accuracy of reporting. In particular, as with MSW, for Member States with co-collection of household and non-household waste, for instance at recycling centres, the separation of waste from households and from commerce and industry may be an estimation. Similarly, the apportionment of waste between NACE sectors may vary considerably between countries.
Furthermore, as noted above, there is not a neat correspondence between WStatR codes and ‘Municipal Waste’ LoW codes. Some WStatR categories include both wastes regarded as municipal waste, and other wastes regarded as non-municipal waste. For instance:
W102 (Mixed and undifferentiated materials) contains LoW chapter 15 code 15 01 05-06 (composite and mixed packaging) and chapter 20 code 20 01 99 (other fractions of household waste), but also ‘wastes not otherwise specified’ from all waste codes, and so may include many wastes that are not similar to household wastes.
Similarly, W091 (animal and mixed food waste) includes LoW chapter 20 codes 20 01 08 (biodegradable kitchen and canteen waste) and 20 01 25 (edible oil and fat), but also waste from LoW chapters 2 and 19.
Therefore, it is not possible to obtain a precise mapping of potential MSW definitions within the WStatR data, and the accuracy of the approach relies upon Member States appropriately segmenting wastes by source. However, it is currently the best dataset
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available, and for most Member States provides a reasonable approximation for the purposes of this comparison.
Finally, it should be noted that this analysis uses data reported in 2012, and that since then Member States may have updated their definitions in use. For example, some Member States who were excluding separately collected packaging waste from their definition of municipal waste may now be including this. Therefore, municipal waste currently reported will be, in some cases, already different than that used in this analysis.
4.5 Household Waste
4.5.1 Definition
The WStatR data distinguishes ‘Households’ as a source of waste, and so Member States reported the quantity of each EWC-Stat category of waste which is generated by households. In the WStatR data, Member States report some waste from households under almost all EWC-Stat waste types.
The starting point for the interpretation of ‘household waste’ in WStatR data is the tonnage reported as waste coming from households. However, there is reason to exclude some of these WStatR categories from our analysis of ‘household waste’ as they are not covered by the traditional scope of municipal waste.
The categories we exclude are:
Spent solvents; acid, alkaline or saline washes; industrial effluent sludges; sludges and liquid waste from waste treatment (W011, W012,W032,W033). The current definition of municipal waste excludes ‘waste from municipal sewage network’ and there is little reason to include it in the analysis presented here. Appendix 9 to the final report of the original Targets Review Project notes that:
“There seems to us to be little reason for including waste from the municipal sewage network and treatment. Yet, as indicated above, Chapter 20 of the List of Waste (which covers municipal waste) includes septic tank sludge (20 03 04) and waste from sewage cleaning (20 03 06), and this falls under category 11 of the EWC-STAT. The positions seem contradictory. It would seem appropriate to exclude 20 03 04 and 20 03 06 to the extent that the quantities of such waste reported would be influenced by connection to the sewage network, and hence, the comparability of waste statistics would be distorted by this factor. It seems appropriate to report generation of this waste, but separately from ‘municipal waste’.”
Sorting residues (so as not to double count wastes in terms of generation); and
Mineral wastes apart from construction and demolition wastes (as they are unlikely to be attributable to households).
We have included waste reported as construction and demolition waste from households. Though excluded in the current definition of municipal waste, it seems likely that the intention of the exclusion of municipal construction and demolition waste is to exclude such waste when resulting from municipal projects, rather than excluding waste that originates
13
from households. Additionally, much construction and demolition waste from households may be in reality collected alongside mixed residual wastes.
Note that the following waste streams additionally have no code in Chapter 20 of the List of Wastes code, yet if Member States have attributed these waste streams to ‘households’ we include them:
Health care and biological wastes;
Rubber ‘end of life tyres’;
Animal waste of food preparation and products; and
Discarded vehicles.
Hazardous waste from households is included in these tonnages from each of the included WStatR types.
Table 4-2: Waste by EWC-Stat Category Mapped onto the ‘Household Waste’ Definition of MSW
EWC-STAT Category Source of Waste
Households
Spent solvents; Acid, alkaline or saline washes; industrial effluent sludges; sludges and liquid waste from waste treatment (W011, W012,W032,W033)
Used oils (W013) Chemical wastes (W02A) Healthcare and biological wastes (W05) Recyclable wastes (W06, W07 except W077) Equipment (included discarded vehicles) (W08A except W0841)
Animal and mixed food waste (W091) Vegetal wastes (W092) Animal faeces, urine and manure (W093) Household and similar wastes (W101) Mixed and undifferentiated materials (W102) Sorting residues (W103) Common sludges (W11) Mineral waste from construction and demolition (W121) Combustion wastes, soils, dredging spoils, mineral waste from soils and dredging spoils (W124, W126,W127)
4.5.2 Comparison with Municipal Waste
Member States are currently reporting municipal waste data at virtually every point on the spectrum of possible interpretation of the definition of municipal waste currently in use (i.e. from household waste only to household waste and similar waste from all non-industrial
14
businesses).13 Thus, the municipal waste reported to Eurostat is, in most cases, higher than that estimated for household waste as we have defined it here.
Figure 4-2 compares the amount of household waste generated, as calculated based on the above definition, to municipal waste as reported to Eurostat in 2012.
Figure 4-2: Household Waste vs Municipal Waste (2012, thousand tonnes)
Source: derived from Eurostat, datasets env_wasgen and env_wasnum
As expected, most countries report some degree of municipal waste over and above that reported as household waste, with a couple of exceptions. In tonnage terms, France and Germany currently report the most additional municipal waste. Overall, municipal waste would have been 14.7% lower than reported in 2012, a difference of over 36 million tonnes, had the definition been confined only to household waste. Figure 4-3 shows for each Member State the breakdown of household waste generated by EWC-Stat waste categories, and the extent of the variation between Member States. It also sets this information against municipal waste reported (indicated by the black bars). A black line above 100% indicates a greater amount of municipal waste than household waste.
13 See, for example, Appendix 1 of Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission Directorate-General for the Environment, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip
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HouseholdWaste
MunicipalWaste
15
Figure 4-3: Breakdown of Household Waste by EWC-Stat Category Reported under WStatR, against Municipal Waste (2012)
Source: derived from Eurostat, datasets env_wasgen and env_wasnum
In 2012, only Latvia and Estonia reported more waste from households than was reported as municipal waste to Eurostat. In Latvia, the municipal waste reported is identical to the tonnage identified within WStatR as being just ‘Household and Similar wastes’ from ‘Households’ – excluding recyclable materials and any separately collected organic wastes that originate from households. The ‘other household waste’ quantity is comparatively large in Latvia, comprising significant quantities of household C&D waste and used oils. Our understanding is that their definition of municipal waste has since been somewhat updated.
Some Member States’ reported municipal waste appears to match this definition: Belgium, Czech Republic, Italy, Portugal and Slovakia – and with minor differences, Sweden and Spain – all report figures for household waste that are more or less the same as what is reported to Eurostat as municipal waste. The potential causes of this include:
municipal waste is defined tightly to exclude commercial wastes; and/or
municipalities in these countries collect very minor quantities of (or no) non-household waste; and/or
waste from offices and small businesses collected by these countries (e.g. through municipal services and through the third sector) are reported to WStatR as from households in source.
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aste
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Organic wastes
Recyclable wastes
Mixed andundifferentiatedmaterials
Household andsimilar wastes
Municipal Waste
16
Belgium and the Czech Republic, for example, use definitions of municipal waste which lean more towards excluding non-household waste, and Slovakia excludes waste “generated by immediate performance of activities representing the subject of business or activities of legal entities or individuals – entrepreneurs”.14
This graph also illustrates the limitations of the EWC-Stat categories and the variation in collection and reporting: whereas for many countries the bulk of waste from households is categorised simply as ‘household and similar waste’, Belgium, on the other hand, reports under 10% of waste from households in this category. With a recycling rate of close to 60%, some residual waste from households was presumably being reported within ‘mixed and undifferentiated materials’. For many countries with bring-site schemes for recycling, the amount of recyclables obtained from households will be an estimated calculation (or will include all the collected recyclables).
4.6 All Household and Similar Wastes
4.6.1 Definition
Whereas ‘Household waste’ is a theoretical minimum for the definition of municipal waste, defining municipal waste as ‘all household and similar wastes’ (regardless of who collects it) should provide a theoretical maximum, and closely resembles the existing definition.
Any definition of municipal waste based on these terms needs a clear definition of the scope of the term ‘similar wastes’. For the purpose of this analysis based upon WStatR data, the definition of similar waste would at least ensure that where possible industrial and commercial waste streams that are significantly different to household wastes are excluded.
An indication of the range of WStatR categories judged by Member States to be included or partially included within the definition of MSW (as defined as household and similar wastes) is shown below in Figure 4-4, a table developed based on the methodological survey on municipal waste carried out in 2010/2011, referenced within the Commission’s Guidance on municipal waste data collection.15,16 As the guidance explains:
“Countries were asked to indicate the cells of table 1 WStatR which are fully or partly covered in their statistics on municipal waste. The number in a cell refers to the number of countries who have marked this cell as being either fully or partly included in municipal waste. The graduation of shadings illustrates the different numbers of countries that marked the cell. The darker the shading of a cell the more countries marked the respective NACE activity and waste item as included in municipal waste.”
14 Source: information extracted from Appendix 1 of Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission Directorate-General for the Environment, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip
15 More details about this survey can be found here: http://circa.europa.eu/Public/irc/dsis/envirmeet/library?l=/municipal_luxembourg/municipal_discussion/_EN_1. 0_&a=d 16 Eurostat (2012) Guidance on municipal waste data collection, available from http://ec.europa.eu/eurostat/documents/342366/351811/Municipal-waste-statistics-guidance.pdf
17
Figure 4-4: WStatR Waste Categories and NACE Codes Included within Municipal Waste Reported to Eurostat
Source: table extracted from Eurostat (2012), Guidance on municipal waste data collection
18
As part of earlier work, Eunomia suggested that this broader definition might sensibly include key waste streams from the services sector (with the exception of wastes from the wholesale of waste and scrap), as the most similar to household waste in nature.17 Several Member States include this data, as reflected in the grey boxes shaded in column 18 above. Other, more industrial sectors (NACE codes A to F), are likely to produce wastes that are qualitatively distinct from household waste and should therefore be excluded from this definition. However, since many companies assigned to a specific NACE code may undertake a variety of activities which are not all associated with ‘industrial production’, it does seem appropriate to include ‘household and similar waste’ reported from all sectors where Member States have identified waste as belonging to this category. This again is broadly in line with the more extended definitions in use by Member States (all the grey boxes in Figure 4-4 above).
Codes included within this Eunomia definition of all household and similar waste therefore include:
‘Household and similar waste’, listed as a distinct waste category (10.1), from all sources.
‘Mixed and undifferentiated materials’ (10.2) from the Services sector – as these might be counted as similar wastes (including potential mixed recyclables and residual waste).
Non-hazardous packaging materials (0.6-0.7) from the Services sector, as these might also be counted as similar in nature to household waste.
The NACE category ‘services’ does potentially include industries from which waste is unlikely to be collected alongside municipal waste streams. However, the WStatR currently does not require further breakdown by source of this waste, so it is not possible to provide a more nuanced analysis here.
Table 4-3 summarises the EWC-Stat Categories that have been included within the definition of ‘all household and similar waste’ considered here. Yellow indicates WStatR waste categories which are included within the scope of household waste, whilst green indicates wastes which are deemed to be ‘similar in nature and composition’ to household waste.
It is worth noting that this is likely to be an over-estimate of municipal waste compared to an attempt to define ‘all household and similar wastes’ based upon LoW codes (which may be preferable, as noted in section 4.4). Some WStatR categories include LoW codes that would not be included within a definition of municipal waste.
17 Appendix 9 of Eunomia Research & Consulting, Copenhagen Resource Institute, and Öko-Institut (2014) Impact Assessment on Options Reviewing Targets in the Waste Framework Directive, Landfill Directive and Packaging and Packaging Waste Directive, February 2014, http://ec.europa.eu/environment/waste/pdf/target_review/Targets%20Review%20final%20report.pdf
19
Table 4-3: Waste by EWC-Stat Category Mapped onto the ‘All Household and Similar Wastes’ Definition of MSW
EWC-STAT Category
Source of Waste
Household Waste
NACE ‘Services’ (Except
Wholesale of Waste and
Scrap)
Other
Spent solvents; Acid, alkaline or saline washes; industrial effluent sludges; sludges and liquid waste from waste treatment (W011, W012,W032,W033)
Used oils (W013) Chemical wastes (W02A) Healthcare and biological wastes (W05) Recyclable wastes (W06, W07 except W077) Equipment (included discarded vehicles) (W08A except W0841) Animal and mixed food waste (W091) Vegetal wastes (W092) Animal faeces, urine and manure (W093) Household and similar wastes (W101) Mixed and undifferentiated materials (W102) Sorting residues (W103) Common sludges (W11) Mineral waste from construction and demolition (W121) Combustion wastes, soils, dredging spoils, mineral waste from soils and dredging spoils (W124, W126,W127)
20
4.6.2 Comparison with MSW Reported
Figure 4-6 compares the volume of MSW currently reported to Eurostat with arisings that would be reported if all Member States were using the definition of all household and similar waste as outlined above.
Figure 4-5: Comparison of all Household and Similar Wastes vs Municipal Waste (2012, thousand tonnes)
Source: derived from Eurostat, datasets env_wasgen and env_wasnum
Overall, municipal waste reported would have been 22.4% higher in 2012 under this definition, with over 55 million additional tonnes reported. Notably, the UK would be the largest contributor of additional tonnage under this definition, and would have reported almost twice as much waste as was reported as municipal waste to Eurostat. France would be the second largest contributor. Germany, Denmark, Poland, Cyprus and Hungary, on the other hand, reported, as municipal waste, marginally more than the amount suggested by this definition.
Figure 4-5 shows the breakdown of this total ‘all household and similar wastes’ municipal waste by source, between Households, Services (excluding wholesale of waste and scrap), and Industry (all other NACE codes apart from wholesale of waste and scrap). It again shows municipal waste as reported to Eurostat, this time as a percentage of ‘all household and similar wastes’.
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MunicipalWaste
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Figure 4-6: Waste within ‘All Household and Similar Wastes’ by NACE rev. 2, Compared Against Municipal Waste (2012)
Source: Eurostat, datasets env_wasgen and env_wasnum
Countries are listed here in order of the proportion of this waste that is currently reported as MSW to Eurostat. In simple terms, the waste above the orange line is currently not reported as MSW. The waste in green below the line is non-household municipal waste currently reported as MSW. Yellow waste above the orange line (for Estonia and Latvia) corresponds to waste recorded as from ‘households’ in EWC-Stat categories not currently included within Member States’ interpretations of MSW (see commentary on Figure 4-3 above).
It is notable that Denmark, Poland, Germany, Cyprus and Hungary all report more municipal waste than is suggested under the broadest interpretation of municipal waste presented here. Denmark only reports very small quantities of waste being generated from the services sector, so it is likely that similar wastes collected from ‘institutions, commerce and offices’ under a municipal scheme – as per their definition of municipal waste – comes from sectors other than those included within the NACE rev.2 category ‘Services’. Some other countries also record very little waste from services and industry within these categories (notably Italy, but also Slovakia and Latvia).
Of the countries which report most of these wastes as MSW (on the left-hand side of the graph above), only Germany operates a door-to-door collection scheme, and is notably comprehensive in its definition of municipal waste. Most others operate, in the main, bring-site schemes, and so may be collecting commercial wastes within their municipal collections. Where a country operates a door-to-door scheme, this analysis suggests that MSW may be under-reported by a factor of 20–40%. This is due to collecting only a fraction of non-household wastes of a similar nature to household waste, and/or to having slightly
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narrower interpretations of municipal waste than under the definition in this Section (for instance, they may exclude packaging wastes from the services industry, or include wastes only from companies below a certain size).
4.7 Household and Similar Wastes Collected by or on Behalf of Municipalities
4.7.1 Definition
Largely for historical and practical reasons, the reporting by many Member States is based on reporting of household and similar waste collected by or on behalf of municipalities. In other words, not all ‘similar waste’ produced by entities other than households is captured in the data. In ‘open-access’ collection systems, such as those predominantly based around bring sites, it is easier to report waste which is actually collected by the municipality, rather than either separating out the household from non-household fractions, or also keeping track of commercial / trade wastes collected by third parties. In countries operating door-to-door collection for households, municipalities, or those collecting on their behalf, often have a degree of discretion as to what non-household wastes they collect, whilst other countries and regions may use regulations to determine what municipalities may, or may not, do.
However, many Member States do also include, within their definition, waste similar to household waste irrespective of who collects it, for instance through collecting data from facility operators who process LoW chapter 15 (packaging) and chapter 20 (municipal) wastes. Conversely, it is also noted that in some cases waste collected by municipalities may not be reported as MSW – LoW chapter 15 wastes, for instance packaging materials collected through bring sites, may not be currently reported as MSW. Definitions further vary, for example, in the inclusion (or otherwise) of estimates of waste dealt with through home composting.
For the purposes of a simplified comparison, we know broadly whether the waste currently reported by Member States matches this definition, or whether the reported figure may also include third-party wastes. The nature of the MSW definition used by Member States – and used within the Municipal Waste Model – is presented in Table 4-4.
Table 4-4: Categorisation of Current Definition of Municipal Waste by Member State
Member State
Definition of MSW
Notes
household waste
collected by or on behalf of
municipalities
household and similar waste
collected by or on behalf of
municipalities
All household and similar irrespective
of who collects it
Austria Yes
Belgium Yes
Bulgaria Yes
Croatia Yes
Cyprus Yes
23
Member State
Definition of MSW
Notes
household waste
collected by or on behalf of
municipalities
household and similar waste
collected by or on behalf of
municipalities
All household and similar irrespective
of who collects it
Czech Republic Clarification was asked on the definition used but no response was received.
Denmark Yes
Estonia Yes Excludes packaging waste.
Finland Yes Home-composted waste is also included.
France Yes
Germany Yes
Greece Yes Greece uses the definition set out in the Landfill Directive.
Hungary Yes
Ireland Yes Includes an estimate of biowaste treated through home composting.
Italy Yes
Latvia Yes Excludes packaging waste.
Lithuania Yes
Luxembourg Yes
Malta Yes
Netherlands Yes
Poland No response
Portugal Yes
Romania Yes
Slovakia Yes
Slovenia Yes
Spain Yes
Sweden Yes
United Kingdom Yes The UK reports on the amount of waste collected by or on behalf of municipalities to Eurostat. However, definitions used within the UK relate to ‘household and similar waste’ and an estimate of this is included in the Municipal Waste Model.
Source: information extracted from Appendix 1 of Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission Directorate-General for the Environment, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip
24
Market cleansing waste (20 03 02) and Street sweepings (20 03 03) might not strictly originate from households, but are ‘municipal’ wastes and are included within the EWC-code ‘household and similar wastes’ (it is unknown whether Member States report this as waste from households or from services).
Therefore, to reach an estimate of quantities of municipal waste under this definition:
For those countries which report their current definition to be waste collected by or on behalf of municipalities, the quantity of MSW reported to Eurostat is used;
For those which report that they include waste collected by third parties within their definition of municipal waste, a country-specific range is reported between household waste collected by municipalities (0% of additional non-household wastes), and as a maximum all household and similar wastes (100% of additional non-household wastes);
These ranges are based on information gathered on commercial waste collections as part of the evidence gathered for the European Reference Model, supplemented with input from country experts.18
4.7.2 Comparison with Municipal Waste
Figure 4-7 shows the potential range in municipal waste quantities using this definition. The actual amount of waste generated under this definition may fall anywhere within the green bars indicated on the graph.
18 Appendix 1 of Eunomia Research & Consulting, Copenhagen Resource Institute, and Öko-Institut (2014) Impact Assessment on Options Reviewing Targets in the Waste Framework Directive, Landfill Directive and Packaging and Packaging Waste Directive, February 2014, http://ec.europa.eu/environment/waste/pdf/target_review/Targets%20Review%20final%20report.pdf
25
Figure 4-7: Comparison of ‘Household and Similar Wastes Collected By or On Behalf of Municipalities’ vs Municipal Waste (2012, thousand tonnes)
Source: derived from Eurostat, datasets env_wasgen and env_wasnum
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MunicipalWaste
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Figure 4-8 below presents the same range as a percentage of municipal waste reported to Eurostat.
Figure 4-8: Household and Similar Wastes Collected by Municipalities, Compared to Municipal Waste Reported to Eurostat (2012)
Source: derived from Eurostat, datasets env_wasgen and env_wasnum
4.8 Comparison of Definitions
Table 4-5 below shows the quantities of waste generated under each respective definition of municipal waste, as described in the above sections, compared with municipal waste as reported to Eurostat. These figures are presented both as overall waste generation, in thousands of tonnes, and in kilograms per head of population (kg/pp).
Table 4-5: MSW Generated Under Each Definition (2012)
Member State
Household Waste All Household and
Similar Waste
Household and Similar Waste
Collected by or on behalf of
Municipalities (central)
Municipal Waste Reported to
Eurostat
Thousand tonnes
kg/pp Thousand tonnes
kg/pp Thousand tonnes
kg/pp Thousand tonnes
kg/pp
Austria 4,018 476 6,523 773 4,883 578 4,883 578
Belgium 4,984 449 9,382 846 5,004 451 5,004 451
Bulgaria 2,755 376 4,147 566 3,364 459 3,364 459
Croatia 1,191 271 1,703 387 1,670 380 1,670 380
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250%
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aste
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Member State
Household Waste All Household and
Similar Waste
Household and Similar Waste
Collected by or on behalf of
Municipalities (central)
Municipal Waste Reported to
Eurostat
Thousand tonnes
kg/pp Thousand tonnes
kg/pp Thousand tonnes
kg/pp Thousand tonnes
kg/pp
Cyprus 409 475 558 647 579 672 579 672
Czech Republic 3,212 306 4,153 395 3,589 342 3,233 308
Denmark 3,472 622 3,879 695 4,242 760 4,242 760
Estonia 429 320 692 517 676 505 371 277
Finland 1,727 320 2,827 523 2,277 422 2,738 507
France 27,213 417 45,919 703 33,947 520 35,001 536
Germany 36,472 446 47,902 585 45,616 557 49,759 608
Greece 4,859 430 6,171 547 5,843 518 5,585 495
Hungary 2,681 269 3,934 395 3,119 313 3,988 400
Ireland 1,657 361 3,658 798 2,693 588 2,693 588
Italy 29,603 487 31,006 510 30,305 498 29,994 493
Latvia 1,139 511 1,344 604 1,241 557 613 275
Lithuania 1,164 353 1,555 472 1,476 448 1,330 404
Luxembourg 248 472 432 823 280 534 346 659
Malta 155 375 276 669 176 427 247 598
Netherlands 8,753 523 13,118 784 9,203 550 9,203 550
Poland 9,324 242 11,485 298 10,405 270 12,084 314
Portugal 4,731 444 5,518 518 4,766 447 4,766 447
Romania 4,647 218 7,077 331 5,441 255 5,441 255
Slovakia 1,643 304 1,875 347 1,666 308 1,657 307
Slovenia 628 306 1,035 504 933 454 744 362
Spain 21,224 459 26,663 577 21,896 474 21,896 474
Sweden 4,105 433 5,174 546 4,907 517 4,304 454
United Kingdom 27,490 436 53,242 845 33,928 539 30,413 483
EU28 209,932 413 301,250 592 244,127 480 246,148 484
Source: estimated based on the definitions described in sections 4.5.1, 4.6.1 and 4.7.1 above, derived from Eurostat, datasets env_wasgen, env_wasmun (extracted 06/10/2015), and proj_13npms
Figure 4-10 and Figure 4-10 display this information, respectively in kg/pp/yr and as a percentage of municipal waste as currently reported. It can be seen from these figures that, depending on the definition used, the amount of municipal waste being generated in a country could vary markedly from the amount reported to Eurostat. The overall variation at
28
an EU level is less pronounced, though it still varies from 85.3% to 125.3% of currently reported municipal waste.
Figure 4-9 displays the difference in municipal waste generated under each definition compared to that reported to Eurostat in 2012. Countries are ordered by the greatest potential percentage increase in waste reported as MSW. The potential range of waste collected by or on behalf of municipalities (where this differs from MSW reported) is indicated by the higher and lower blue bars.
Figure 4-9: Municipal Waste Generated Under Each Definition, % of Municipal Waste Currently Reported (2012)
Source: derived from Eurostat, datasets env_wasgen and env_wasnum
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Figure 4-10: Municipal Waste Generated Under Each Definition, kg/pp/yr (2012)
Source: derived from Eurostat datasets env_wasgen and env_wasnum
Figure 4-11: Municipal Waste Generated Under Each Definition, kg/pp/yr (2012)
Source: derived from Eurostat datasets env_wasgen and env_wasnum
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As Figure 4-10 and Figure 4-11 indicate, there is significant variation in municipal waste generation per inhabitant between Member States, regardless of the definition in use. The waste generated per person per year for ‘household and similar waste’, which most closely corresponds to the way in which Member States should be reporting their data on Municipal Waste (in line with the definition), ranges from 276kg to 846kg between Member States.
The ‘household and similar waste’ measure may (though this would require closer investigation) also show a marginally stronger association with GDP per capita, as shown in Figure 4-12 below. The strength of correlations will vary depending on the parameter against which waste arisings are being compared and the definition of municipal waste that is being used.
Figure 4-12: Correlation of GDP per Capita with Municipal Waste Definitions
Source: derived from Eurostat, datasets env_wasgen and env_wasnum compared with gross domestic product at market prices.
4.9 Conclusions
This exercise illustrates the range in waste that might be reported under each of three potential definitions of municipal waste, relying on data reported by source under the Waste Statistics Regulations. This dataset highlights some of the complexities in the definitions currently in use, and it is likely that this data in some cases over-estimates, and in others under-estimates, the amount of waste which we are seeking to include under each definition. This is due to there not being a precise match with the WStatR categories, and to the variation in Member States’ interpretation of these categories and data collation systems.
R² = 0.3891
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It is important to note that some Member States would accept a more granular definition than that proposed here, and it is important to bear in mind the distinction between defining a range of wastes that municipalities may be required to have some level of responsibility for, and defining a range of wastes for the purposes of setting and measuring recycling targets.
Were a definition to be based on what municipalities choose to collect, wastes reported as ‘municipal waste’ are likely to continue to differ greatly between Member States, depending on the scope of their collection systems. However, under this analysis the overall amount of waste reported as Municipal Waste will not greatly vary from that currently reported – between a 4.5% reduction and a 2.5% increase. This is due to the fact that many Member States currently use these figures as their interpretation of the definition, and that tonnages reported from some countries (notably Germany, France, Hungary and Poland) are assumed to decrease, balancing out increases in waste tonnages in the United Kingdom and elsewhere.
The alternative option is to define wastes based on the types of waste generated. There is a clear desire to include waste from small businesses within the definition, and it makes sense to include household-like waste from commercial businesses within the scope of recycling targets, as many Member States already do in part. This ought to improve the comparability of data across Member States assuming that the types of waste being generated can be consistently identified, and data on their generation can be readily acquired.
Based on our analysis, the ‘all household and similar wastes’ definition would have increased the quantity of municipal waste reported in 2012 by 22.4%, to just over 300 million tonnes, with 11 Member States having to increase the amount reported by them by over 50%. Whereas the WStatR dataset is poorly able to reflect this, definitions based on a combination of LoW codes and sources have been recommended for the purposes of creating a consistent expanded scope of waste for recycling targets.
It should be noted that the definition used is likely to affect the reported recycling performance. Whether the reported performance increases or decreases depends both on the starting point for a given Member State (both in terms of the implied definition currently used, and the current level of performance) and the extent to which recycling performance differs between household and non-household sectors.
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5.0 Measuring Recycling Performance
It is widely recognised that there is very little consistency in the way Member States report against the various recycling targets. This is further exacerbated by the fact that Member States are allowed to report against the 50% MSW preparation for reuse / recycling target using one of four calculation methods.19 A recurring theme that emerged from the work on the revision of the European waste management targets concerned the need to improve the consistency in the way in which Member States reported against the recycling targets.20 The need to address inconsistencies and the lack of harmonisation in reporting was frequently cited as a key concern by stakeholders from all backgrounds. Addressing these issues has, therefore, been a key priority for the Commission.
This Section provides a detailed examination of how the measurement of ‘recycling’ and ‘preparation for reuse’, for the purposes of measuring performance against targets in the Waste Framework Directive and the Packaging and Packaging Waste Directive, may be improved and harmonised. This is not a discussion about different ways of meeting the 50% recycling target, but rather a discussion about what should count as ‘recycling’ and ‘preparation for reuse’.
As required by the Terms of Reference for the project, the work presented in this Section was mostly undertaken prior to the publication of the revised legislative proposal in December 2015. The discussions below, therefore, provide some suggestions of how the measurement method could be structured but do not explicitly consider the exact phrasing of the measurement method put forward by the Commission in the revised text for Directive 2008/98/EC and Directive 94/62/EC. Some initial reactions to the Commission proposal presented in December 2015 have, however, been taken into account in the conclusions presented in Section 5.6.
In order to explain the context and background for the suggested approach we first examine some important background information and supporting evidence. This Section of the report includes the following sub-sections:
Section 5.1 – provides an overview of the current legislation governing reporting on the recycling targets in the Waste Framework Directive and the Packaging and Packaging Waste Directive and introduces the revised proposal for how the Commission suggests that this may be dealt with;
Section 5.2 – summarises the feedback that has been received from Member States as part of the Commission’s Member State consultation which was held over the summer of 2015;
19 See Commission Decision 2011/753/EU Establishing Rules and Calculation Methods for Verifying Compliance with the Targets set in Article 11(2) of Directive 2008/98/EC of the European Parliament and of the Council, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32011D0753 20 Eunomia Research & Consulting, Copenhagen Resource Institute, and Öko-Institut (2014) Impact Assessment on Options Reviewing Targets in the Waste Framework Directive, Landfill Directive and Packaging and Packaging Waste Directive, February 2014, http://ec.europa.eu/environment/waste/pdf/target_review/Targets%20Review%20final%20report.pdf
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Section 5.3 – examines some of the challenges associated with tracking waste materials from the point of collection through to a final recycling process and how these challenges may be dealt with;
Section 5.4 – presents the results of a literature review which identified studies which have quantified the amounts of materials being lost from the supply chain through sorting and recycling processes;
Section 5.5 – summarises examples of the standards / industry specifications that govern contaminant tolerance thresholds for different secondary materials; and
Section 5.6 – concludes by discussing options for possible modifications of the measurement method, inter alia to include material specific thresholds and enhance clarity.
5.1 Legislative Background
The existing rules governing reporting on municipal recycling rates under the Waste Framework Directive are set out in Commission Decision 2011/753/EU. This Decision stipulates that:
“The weight of the waste prepared for reuse, recycled or materially recovered shall be determined by calculating the input waste used in the preparation for reuse or the final recycling or other final material recovery processes. A preparatory operation prior to the submission of the waste to a recovery or disposal operation is not a final recycling or other final material recovery operation. Where waste is collected separately or the output of a sorting plant is sent to recycling or other material recovery processes without significant losses, that waste may be considered the weight of the waste which is prepared for reuse, recycled or has undergone other material recovery” 21 (emphasis added).
The reporting requirements for the Packaging and Packaging Waste Directive have been set out in Commission Decision 2005/270/EC and are similar to those identified above:
“The weight of recovered or recycled packaging waste shall be the input of packaging waste to an effective recovery or recycling process. If the output of a sorting plant is sent to effective recycling or recovery processes without significant losses, it is acceptable to consider this output to be the weight of recovered or recycled packaging waste” 22 (emphasis added).
The main difference between these two definitions related to the fact that targets in the Waste Framework Directive can be reported in terms of waste collected, whereas for the Packaging Waste Directive, the earliest point at which reporting can occur is at the output from a sorting plant.
21 Article 2(2) in Commission Decision 2011/753/EU Establishing Rules and Calculation Methods for Verifying Compliance with the Targets set in Article 11(2) of Directive 2008/98/EC of the European Parliament and of the Council, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32011D0753 22 Article 3(4) in Commission Decision 2005/270/EC Establishing the Formats Relating to the Database System Pursuant to Directive 94/62/EC of the European Parliament and of the Council on Packaging and Packaging Waste, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32005D0270
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The inclusion, in both definitions, of the term “without significant losses” is apt to cause some confusion since there were no criteria mentioned that could be used to determine what should be considered as a ‘significant loss’. One suspects that, partly for this reason, many Member States do not understand the extent of the material losses that occur after collection, or after sorting, and prior to the point of “final recycling” or “effective recovery or recycling”. For example, feedback received as part of a Member States consultation included statements which suggested that some countries paid little regard to the notion of ‘significant losses’. For example, some countries assumed that, in general, ‘significant losses’ did not occur after the point of collection when materials were collected as separate streams at source, but at the same time pointed to surveys estimating difference between the collected amount for recycling and the actual recycled amount at 6% for glass waste, 15% for paper waste, 20% for plastic waste, and 10-24% for food waste. Without clear guidance on what constitutes significant losses, loss rates may appear non-significant to some, while to others, these rates may appear quite high. There is a strong likelihood that the losses also vary by collection system, and by material.
It was the Commission's view that these rules were in need of clarification in order to ensure uniform implementation and comparability of data across the EU, while avoiding, as far as possible, potential misinterpretation, or abuses, and excessive administrative burdens. There is also recognition of the fact that allowing for inclusion of losses which may or may not be significant within reported recycling rates may have the effect of lowering the quality of collection systems. Recognising the ambiguity in the above requirements, the Commission set out to refine the measurement method in the original legislative proposal published in July 2014.23 In this proposal, the Commission suggested that the following procedure be adopted for measuring performance against the proposed municipal, and packaging, waste recycling targets:
“…the weight of the waste prepared for reuse and recycled shall be understood as the weight of the waste which was put into a final preparing for reuse or recycling process less the weight of any materials which were discarded in the course of that process due to presence of impurities and which need to be disposed of or undergo other recovery operations. However, where the discarded materials constitute 2% or less of the weight of the waste put into that process, the weight of the waste prepared for reuse and recycled shall be understood as the weight of the waste which was put into a final preparing for reuse or recycling process.” 24
23 European Commission (2014) Proposal for a Directive of the European Parliament and of the Council Amending Directives 2008/98/EC on Waste, 94/62/EC on Packaging and Packaging Waste, 1999/31/EC on the Landfill of Waste, 2000/53/EC on End-of-Life Vehicles, 2006/66/EC on Batteries and Accumulators and Waste Batteries and Accumulators, and 2012/19/EU on Waste Electrical and Electronic Equipment, COM(2014)397, July 2014, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52014PC0397 24 European Commission (2014) Proposal for a Directive of the European Parliament and of the Council Amending Directives 2008/98/EC on Waste, 94/62/EC on Packaging and Packaging Waste, 1999/31/EC on the Landfill of Waste, 2000/53/EC on End-of-Life Vehicles, 2006/66/EC on Batteries and Accumulators and Waste Batteries and Accumulators, and 2012/19/EU on Waste Electrical and Electronic Equipment, COM(2014)397, July 2014, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52014PC0397
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Responses to this proposal indicated that a more flexible approach might be needed and that this may have to be based on material specific limits which more clearly reflected current operational realities. Eunomia considered the measurement method in some detail to identify the extent of the challenge posed by the 2% limit and to ensure that ambiguity in the definition was minimised as far as possible.
Eunomia considered the following approach for establishing the measurement method for assessing Member State performance against the Waste Framework Directive and the Packaging Waste Directive targets:
1) For the purpose of calculating whether the targets have been achieved, a) the weight of the waste "recycled" shall be understood as the weight of the
input waste entering the final recycling process; b) the weight of the waste "prepared for reuse" shall be understood as the
weight of the waste that has effectively undergone all necessary checking, cleaning and repairing operations to enable reuse without further sorting or pre-processing.
2) By way of derogation from Paragraph 1, the weight of the output of any sorting operation may be reported as the weight of the waste “recycled” provided that:
a) such output waste is introduced into the final recycling process; b) the weight of materials or substances that are not targeted either by
separate collection or the final recycling process and that are further landfilled or incinerated remains below 10% of the total weight to be reported as recycled. Losses in weight of materials or substances due to physical and/or chemical transformation processes inherent to the recycling process shall not be considered;
c) an effective system of quality control and traceability of the waste is in place to ensure that conditions under a) and b) are met. For this purpose Member States shall either establish an electronic or technical specifications for the quality requirements of sorted waste or any equivalent measure to ensure the reliability, accuracy of the data gathered on recycled waste.
Member States shall communicate to the Commission the list of measures ensuring that an effective system of quality control and traceability of the waste is in place.
3) Waste exported from the Union for preparation for reuse or recycling shall only count towards the achievement of the targets in respect of the Member State in which it was collected if the requirements of paragraph 2(c) are met and the exporter can prove in compliance with Regulation (EC) No 1013/2006 that the treatment outside the Union took place under conditions that are equivalent to the requirements of the relevant Union environmental legislation.
This approach provides greater clarity than the proposal put forward in the 2014 legislative proposal. However, it was considered that there were still a number of clarifications that could be made to provide more certainty and consistency in interpretation. For example, it is not clear if the condition that “Losses in weight of materials or substances due to physical and/or chemical transformation processes inherent to the recycling process shall not be considered” applies to the whole recycling process or just the final recycling process. If the
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former interpretation is considered it would mean that factors such as moisture losses, which are inherent to any recycling process – especially where collection systems mean that material are exposed to the elements – would not be considered. If these ‘inherent’ losses are restricted to the final recycling process, it would only affect factors such as the loss of paper fibres which are too short to be recycled. The point at which it is acceptable to report separately collected materials as having been recycled should also be clarified given that materials which are separately collected (and kept separate) are often sent to a final recycling process without prior sorting.
5.2 Member State Consultation
Member States were consulted directly via means of a short questionnaire issued by the European Commission in July 2015. A total of 20 Member States responded to the consultation. This questionnaire included the following three questions:
1) At what stage in the waste management process do you measure quantities to be reported as recycled / prepared for reuse? Does this measurement point vary depending on the waste fraction or material stream? If the measurement takes place before waste reaches the final recycler, how do you ensure that "significant losses" do not occur after measurement?
2) What is the approximate share of municipal and packaging waste generated in your country sent to a final recycler located in another MS? What is the approximate share sent to a final recycler located in another MS outside the EU?
3) In your view, what would be the most appropriate single point of measurement to obtain reliable and comparable data while limiting administrative burden (e.g. output of first sorting operation, output of last sorting operation, input to the final recycler, etc.)? Please motivate your choice.
There are a number of points in the supply chain at which recycling can be measured – a graphical representation of these points is presented in Figure 5-1. Broadly speaking, Member States stated that they report on the total amount of waste that is recycled in four different ways:
1) By reporting the amount of material that is collected for recycling; 2) By reporting the amount of waste that exits a sorting process; 3) By reporting the amount of waste that is sent to a final recycler; and 4) By reporting the total amount of material that is used in the final recycling process
(i.e. the reporting takes into account any sorting that takes place at the final recycling facility itself).
No Member States reported tracking materials all the way through to the output of the final recycling process where the input materials were made into new products, materials, or substances.
It was not always entirely clear how the response should be categorised. For example, some Member States’ responses referred to inputs to ‘recycling processes’ and others to ‘final recycling process’, this highlighting the need for clarity in defining when the recycling process starts. Where municipal waste is concerned, a number of countries reported using different points of measurement.
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Figure 5-1: Points in the Supply Chain at which Recycling Tonnages can be Measured
Key
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1st Material Sorting
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material losses
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been sorted to remove impurities
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process
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some rudimentary sorting may occur (e.g.
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Where municipal waste is concerned, a number of Member States continue to report, as recycled, the quality of material collected for recycling. Several Member States report material as recycled once it comes out of a sorting facility. Where municipal waste is concerned, it may well be that this can be taken to imply the output of the first sorting facility, even though some materials, notably, mixed plastics (i.e. plastics that include more than the empty plastic bottles) might pass through subsequent sorting stages. A small number of Member States report on the quantities input into final recycling facilities, but in such a way that any sorting at those facilities does not appear to be taken into account (this is not always entirely clear).
Relatively few Member States commented specifically on biowastes, and how they accounted for the reporting of these in the context of the recycling rates. Article 2(6) of Commission Decision 2011/753/EU states:
“Where the target calculation is applied to the aerobic or anaerobic treatment of biodegradable waste, the input to the aerobic or anaerobic treatment may be counted as recycled where that treatment generates compost or digestate which, following any further necessary reprocessing, is used as a recycled product, material or substance for land treatment resulting in benefit to agriculture or ecological improvement.”
Some Member States noted that they report, as recycled, the biodegradable outputs from MBT plants, with relevant adjustments and making relevant estimates (see Section 7.0 for further details on the extraction of organic materials from MBT facilities).
A complicating factor in the assessment is the quantity of material sent outside the Member State for recycling. A number of Member States do not appear to report anything other than the quantity of material exported. Some Member States do, however, have significant shares of exports in their total recycling: these countries include Denmark, Estonia, Malta, Spain and UK. In these cases, any losses post-export would not be accounted for irrespective of the method which was intended to be applied to materials kept within the Member State. In other words, even if the Member State sought to track materials through to the final recycling process within its own borders, if a substantial proportion of material was exported, then any subsequent losses would not be properly accounted for, however large or small they might be, unless loss rates were estimated and deducted.
Just over half (55%) of Member State respondents stated that their preference would be to set the measurement point for the municipal/packaging waste targets after sorting had occurred and before the material enters the final recycler. The next most popular option was to measure the targets based on the amount of waste sent for recycling after the first treatment/sorting process. In practice, in most cases these two options are likely to amount to the same thing. Only two of the 20 respondents felt that recycling should be measured against the total amount of waste collected for recycling.
Despite the clear preference for measuring recycling further downstream, Member States highlighted some of the challenges that would be involved in doing this:
The mixing and movement of waste streams would make it difficult to track materials to a final recycling facility;
Accounting for reject losses along the supply chain would result in lower reported recycling rates;
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Tracking the fate of materials which have been exported poses a number of challenges; and
Recording waste flows along the supply chain would increase the administrative cost of gathering the required data.
5.3 Tracking Waste Materials
It is worth examining some of the key challenges that countries may face in tracking materials to the final recycling process and how these could potentially be addressed.
5.3.1 Challenges Associated with Quantifying Waste Flows
It is clear that there are various stages at which losses can occur in the passage of materials from the point at which they are collected to the point at which they are actually recycled. Furthermore, material losses may be of different types. One may think of the mass flow process from collection to recycling as being reminiscent of a ‘tree’ whose branches represent the different streams into which waste is sorted. These branches link one process to another, with each process potentially being the source of more branches. With each processing stage representing a branching point, there are likely to be losses at each stage.
These losses may include:
Non-target substances, i.e. materials which were not being sought by the collection scheme (e.g. liquids in the collection of plastic bottles). Note that where non-target materials are sorted from a stream, it is possible that they may be recycled;
Materials of the targeted type, but not desired by a given process (e.g. some plastic fractions may be collected as part of ‘plastics’, but are not recycled); and
Materials of the targeted type which could have been recycled, but which were either lost in sorting processes, mis-sorted into the wrong product stream, or attached to materials which were considered as contaminants. Some of these materials may subsequently be recycled.
The losses will depend upon:
How the material is collected;
The communications accompanying the service (and related to this, the accuracy of sorting by households);
The need (or otherwise) for sorting;
The quality of the sorting process;
The extent to which the sorting process is run at full capacity; and
The processes which the material has to be subjected to ‘post sorting’ (for example, some sorting plants might produce a mixed polymer stream of plastics which requires further sorting).
The requirement to report on recycling to the point of final reprocessing can be challenging for materials which pass through multiple facilities and/or merchants. A graphical example of the mixing of waste streams is presented in Figure 5-2. This Figure shows how two different waste streams mix and split as they pass from one facility to the next. In this example, co-mingled recyclables collected by, or on behalf of, a municipality (yellow blocks) are sent to a primary Material Recovery Facility (MRF) for initial sorting, along with waste
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from other municipal and/or non-municipal sources (green blocks). It is clear that, once collected, there are numerous flows of materials that may arise, and a large number of points in the movement of waste at which materials may be lost as rejects. There are circumstances where material ‘unwanted’ by a specific process can be recycled – for example, some processes may be used to dealing with contraries and have specific sorting lines of their own to extract not-target materials, not for disposal but for recycling.
Figure 5-2: Hypothetical Example of the Mixing and Movement of Waste Materials Sent for Recycling
A further complication is that the primary MRF may apply EWC codes that do not allow the waste to be identified as coming from municipal origins (e.g. by using the EWC 15 category
Key
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material losses
material losses material losses
etc.
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waste streams before reaching a final recycling process
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for waste packaging). Where mixing of municipal waste streams occur it can be very challenging to track materials from one facility/merchant to the next and therefore to know if materials are, or are not, municipal waste. As materials pass between operators and/or merchants it is also likely that they will apply different EWC codes and that material may be stockpiled for periods of time when material values are low. Such practices can lead to further challenges in tracking materials within a given reporting period. This suggests the importance of: a) accurate classification of wastes; and b) potentially, the desirability of linking the definition of municipal waste to European waste codes so as to promote consistency of reporting (see Section 3.0 for more details on this).
In order to report on material losses along the supply chain it will be necessary to quantify the flows of material from source to the ‘final recycling process’ or an appropriate ‘end destination’ (e.g. landfill). The length, size, and complexity of these flows will depend significantly on the point at which the waste material is deemed to have reached a ‘final recycling process’ or its ‘end destination’. If consistency in reporting is to be ensured, it is essential that there is a common understanding of the term ‘final recycling process’ / ‘end destination’.
Mapping the movement of waste materials to their end destination precedes the more onerous and complex task of assigning material flows (i.e. tonnages) to each branch of what could be likened to a ‘waste movement tree’. Three examples of actual waste movements in the United Kingdom are provided below for glass (Figure 5-3), steel cans (Figure 5-4), and mixed plastics (Figure 5-5). From the complexity of the waste flows, particularly for plastics, it is evident that a set of core definitions will be essential if Member States are to report in a consistent manner and accurately account for the flow of materials. In order to provide clarity in this area, a discussion of key concepts and definitions is presented in Section 5.4.
Figure 5-3: Example Waste Movement Tree for Glass Collected via a Co-mingled Collection Service in the United Kingdom
Example of Waste Movement Tree
Municipal waste input material
Other input material
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Final recycling process
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Glass reprocessor
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Steel
Aluminium
Glass
Commercial waste
Landfill
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Recycled contraries
Product
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Figure 5-4: Example Waste Movement Tree for Steel Cans Collected via a Co-mingled Collection Service in the United Kingdom
Example of Waste Movement Tree
Municipal input material
Other input material
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Final end destination assumed
Final recycling process
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Steel cans
Co-mingled wasteCommercial
waste
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Steel smelter
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Steel melt
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Landfill
Steel cans
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Process slag
Steel smelter
Process slag Steel melt
Steel
Recycled
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further sorting with other co-mingled
material
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Sorting rejects
Other municipal waste
Material flows
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Figure 5-5: Example Waste Movement Tree for a Mixed Plastics Stream Collected via a Co-mingled Collection Service in the United Kingdom
5.3.2 Options for Tracking Waste Flows
The revised approach to measuring recycling performance presented in Section 5.1 clearly demonstrates the intention that Member States report recycling at the point of final recycling. As part of the 2014 legislative proposal for the Waste Framework Directive,25 the following paragraph was to be added to Article 35 of the Directive:
25 European Commission (2014) Proposal for a Directive of the European Parliament and of the Council Amending Directives 2008/98/EC on Waste, 94/62/EC on Packaging and Packaging Waste, 1999/31/EC on the
Example of Waste Movement Tree
Municipal input material
Other input material
Sorting facility
Final end destination
Final end destination assumed
Final recycling process
Non-hazardous landfill
Key
Co-mingled waste Commercial waste
Primary Sorting Facility
Plastic Reclamation Facility
Landfill
Film, HDPE &mixed rigid
plastics
Mixed material stream sent for further sorting with other co-mingled
material
Exported
Reprocessing rejects
EfW
Steel
Aluminium
Superclean material sold to UK market; other material used
for food grade packaging
Secondary Sorting Facility
Superclean material sold to make high density strapping
Recycled contraries
Clear PET
Coloured PET
HDPE Natural
60% to UK market and 40% to Europe
HDPE Jazz
100% to UK market
Other plastics
(PP & PS)
Landfill
Exported
Film
Film, HDPE &mixed rigid
plastics
Product streams treated in a similar manner to that identified above.
Landfill
Sorting rejects
Sorting rejects
Other municipal
Material flows
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“Member States shall set up an electronic registry or coordinated registries to record data on hazardous waste and, where appropriate, other waste streams, covering the entire geographical territory of the Member State concerned. Member States shall use the data on waste reported by industrial operators in accordance with the European Pollutant Release and Transfer Register set up under Regulation (EC) N° 166/200626”.
If electronic registries were to play a role in tracking the flows of municipal and packaging waste it would be necessary for Member States to adopt such systems for all waste flows, as is already done in a number of countries around the world. Europe’s single market provides a unique opportunity for trying to develop a single system that could be integrated across Member States, and which would also allow for cross-border movements of waste to be tracked far more easily.
Eunomia reviewed a number of electronic registries in Appendix 8 of the technical documentation which accompanied the study to support the 2014 waste targets review.27 One of these was the European Data Interchange for Waste Notification Systems (EUDIN), which has been set up between a select number of EU Member States to track the import and export of waste (Box 1). Such schemes, if set up correctly, could be used to improve the tracking of waste from source to ‘end-destination’ (i.e. the point at which materials are disposed of in landfill or reprocessed). Although tracking materials in this way is not free of challenges, there are some important benefits that such a system could help to deliver in terms of improving the quality of the available data on imports and exports of municipal waste. It is believed that electronic registries are one of the most effective ways of tracking waste flows at the national level.
When setting up electronic registries the primary challenges that will be faced include:
Lack of a clear definition of what constitutes municipal waste;
Tracking waste movements from source to end-destinations; and
Lack of relevant legal frameworks.
Each of these points is discussed briefly below.
Landfill of Waste, 2000/53/EC on End-of-Life Vehicles, 2006/66/EC on Batteries and Accumulators and Waste Batteries and Accumulators, and 2012/19/EU on Waste Electrical and Electronic Equipment, COM(2014)397, July 2014, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52014PC0397 27 Eunomia Research & Consulting, Copenhagen Resource Institute, and Öko-Institut (2014) Impact
Assessment on Options Reviewing Targets in the Waste Framework Directive, Landfill Directive and
Packaging and Packaging Waste Directive, February 2014,
http://ec.europa.eu/environment/waste/pdf/target_review/Targets%20Review%20final%20report.pdf
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Box 1: European Data Interchange for Waste Notification Systems (EUDIN)
The European Data Interchange for Waste Notification Systems (EUDIN) is a:
“… framework of standardised interfaces, business rules and runtime system components that enable the seamless exchange of messages dealing with the transport, receipt and recovery/disposal of waste across borders between the Member States of the European Union and other interested countries”.28
In essence, the system is intended to aid the exchange of data between European Member States as part of efforts to enable the electronic transposition of the requirements of the Waste Shipment Regulations. The EUDIN system was developed through a number of partners, including Austria, Belgium, Germany, Luxembourg and the Netherlands. At present, it appears as if only Belgium, Germany and Luxembourg are making use of the system, although the intention is to open up the platform to other Member States in the near future.29
Figure 5-6: Overview of the EUDIN System
Source: European Data Interchange for Waste Notification Systems, www.eudin.org/ms/eudin/eudin_factsandfigures/
If an EU wide electronic registry were to be developed it would be necessary (in the absence of a clear definition of municipal waste) to devise a mechanism for tracking municipal waste
28 EUDIN (2014) Facts & Figures, Date Accessed: 11th November 2014, Available at: www.eudin.org/ms/eudin/eudin_factsandfigures/ 29 Ibid.
EUDIN MESSAGE BROKER WITH AUTOMATED
EXCHANGE
WASTE MOVEMENT INTERFACE
COMPETENT AUTHORITY OF
EXPORT
NATIONAL APPLICATION
COMPETENT AUTHORITY OF
IMPORT
NATIONAL APPLICATION
COMPETENT AUTHORITY FOR
TRANSPORT
NATIONAL APPLICATION
WASTE NOTIFIER
Notifiers provide data on waste exports and via their national application get access to movement announcement
(MA), written confirmation of receipt of the waste by the facility (COWR), and certificate for non-interim recovery or
disposal by the facility (COWD).
WASTE FACILITY
Facilities provide data on the receipt and disposal/treatment of waste. Via their national application facilities get access to movement announcement
(MA), written confirmation of receipt of the waste by the facility (COWR), and certificate for non-interim recovery or
disposal by the facility (COWD).
46
to its point of export. Where mixing occurs and waste is sent off to multiple facilities/merchants it would be necessary to apply some apportionments in order to estimate what proportion of the municipal waste is going where. This is not a straightforward process and would require knowledge of the volumes of waste being delivered to a facility by different operators so that material losses and outputs could be apportioned appropriately based on the volume of incoming material.
The UK’s edoc electronic system, for example, provides users with an optional tracking system with which to follow the fate of one’s waste.30 However, it is not clear exactly how this tracking occurs and to what extent it can follow individual materials, such as, plastics, whose pathway towards a final recycling process can be rather complex (by final recycling process we do not mean the point at which it is exported, but rather the point at which it is recycled).31 It is worth noting that in many instances – especially where materials are collected separately at source and sent directly to final reprocessors – it can be relatively easy to track materials. The example given above applies more to materials which require additional sorting and processing before they are sent to a final reprocessor, or to instances where materials pass through multiple hands on their way to their end destination.
5.4 Quantifying Material Losses
A literature review of publicly available information was undertaken to identify studies that quantify typical material loss rates that occur between the point at which wastes are collected and their final reprocessing (the full review is presented in Appendix A.3.0). There are clear challenges in such a review, as there is no standard procedure for measuring and defining such losses. For example, some studies only look at the amount of material lost during the sorting phase, while others consider losses arising from both sorting and reprocessing operations. Although not explicitly stated, it would also appear that many studies include moisture losses in their calculations which can be quite substantial for certain materials. Some studies have also taken to reporting losses as being any non-target material that is diverted away from a sorting or recycling process irrespective of whether it subsequently gets recycled or not (e.g. metal lids extracted from a glass stream may count as ‘losses’ in some studies even if they are ultimately separated out and sent to a final recycling process).
The review presented in Appendix A.3.0 builds on earlier research undertaken by Eunomia used to inform the development of the European Reference Model on Municipal Waste Management.32 Since the publication of the Commission’s legislative proposal in July 2014, a
30 edoc (undated) Electronic Duty of Care: The New Way to Record Waste Transfers, Slide Presentation Developed by edoc, http://edoconline.co.uk/resources/edoc-presentation/
31 The Article 3(17) of the Waste Framework Directive considers waste to have been recycled when it has been
“reprocessed into products, materials or substances whether for the original or other purposes.” This is still ambiguous in terms of defining when a final reprocessor has been reached, but it is clear it is not the point at which waste materials are exported abroad for further reprocessing. 32 See Section 3 in Appendix 5 of Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission
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number of studies have been undertaken to provide evidence on the actual rates of material losses. A summary of the reported loss rates across a range of studies is provided in Table 5-1. It is clear from the studies reviewed that material losses along the supply chain vary from material to material and can be relatively high for certain materials. Mixed plastic polymers, for example, are reported in a number of studies as having high levels of material rejected and sent for thermal recovery or disposal. Materials which are easier to sort, such as steel cans, typically have much lower reject rates. Some of these materials can also be more easily extracted for subsequent recycling when they end up as contamination in another product stream. This helps to reduce the overall quantity that ends up being disposed of (e.g. metal lids extracted from glass cullet will typically be extracted and sent for recycling).
Directorate-General for the Environment, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip
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Table 5-1: Summary of Studies Reporting on Material Loss Rates
Material Waste Steam Collection System Sorting Losses Recycling
Losses Total Reported
Losses Source
Glass Glass
Household
Not defined Included Included 6% 1
Sorted on the vehicle Included Included 0% 2
Single Stream Co-mingled Included Included 7% 2
Two-stream Co-mingled Included Included 6% 2
Not defined Included (8%) Included (5%) 12.6% 6
Co-mingled n/a n/a 7.2%33 11
Commercial / Industrial Not defined Included (1%) Included (5%) 6% 6
Packaging Not defined Uncertain Included 10% 7
Paper / Card
Paper Household Not defined Included Included 15% 1
Brown board
Household
Sorted on the vehicle Included Included 3% 2
Single Stream Co-mingled Included Included 11% 2
Two-stream Co-mingled Included Included 8% 2
Grey & white board
Sorted on the vehicle Included Included 4% 2
Single Stream Co-mingled Included Included 14% 2
Two-stream Co-mingled Included Included 10% 2
Newspapers & Pamphlets
Sorted on the vehicle Included Included 1% 2
Single Stream Co-mingled Included Included 7% 2
Two-stream Co-mingled Included Included 4% 2
Paper & card Not defined Included (4%) Included (10%) 13.60% 6
Co-mingled n/a n/a 2.9%34 11
Paper & card Commercial / Industrial Not defined Included (2%) Included (10%) 11.80% 6
Paper & card Packaging Not defined Uncertain Included 15% - 30% 7
33 Average level of non-target materials in the output of sorting facilities in England. 34 Average level of non-target materials in the output of sorting facilities in England.
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Material Waste Steam Collection System Sorting Losses Recycling
Losses Total Reported
Losses Source
Drinks cartons Packaging Not defined Uncertain Included Circa 25% 7
Plastics
Mixed plastics Household Not defined Included Included 20% 1
Plastic bottles
Household Sorted on the vehicle Included Included 1% 2
Household Single Stream Co-mingled Included Included 11% 2
Household Two-stream Co-mingled Included Included 8% 2
Plastic film (LDPE)
Household Sorted on the vehicle Included Included 6% 2
Household Single Stream Co-mingled Included Included 67% 2
Household Two-stream Co-mingled Included Included 62% 2
Other dense plastic packaging
Household Sorted on the vehicle Included Included 7% 2
Household Single Stream Co-mingled Included Included 62% 2
Household Two-stream Co-mingled Included Included 51% 2
Other dense plastic (non-packaging)
Household Sorted on the vehicle Included Included 7% 2
Household Single Stream Co-mingled Included Included 77% 2
Household Two-stream Co-mingled Included Included 73% 2
All plastics
Household Sorted on the vehicle Included Included 3% 2
Household Single Stream Co-mingled Included Included 38% 2
Household Two-stream Co-mingled Included Included 28% 2
Mixed plastics
Household Not defined Included Not included 40% 3
Household Not defined Included Not included 25% 4
Household Not defined Included (25%) Included (29%) 46.80% 6
Household Co-mingled n/a n/a 8.9%35 11
Mixed plastics Commercial / Industrial Not defined Included (5%) Included (5%) 9.80% 6
Packaging Not defined Uncertain Included 15% - 30% 7
35 Average level of non-target materials in the output of sorting facilities in England.
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Material Waste Steam Collection System Sorting Losses Recycling
Losses Total Reported
Losses Source
Metals
Ferrous cans
Household Sorted on the vehicle Included Included 2% 2
Household Single Stream Co-mingled Included Included 8% 2
Household Two-stream Co-mingled Included Included 4% 2
Other ferrous
Household Sorted on the vehicle Included Included 15% 2
Household Single Stream Co-mingled Included Included 62% 2
Household Two-stream Co-mingled Included Included 62% 2
All ferrous
Household Sorted on the vehicle Included Included 2% 2
Household Single Stream Co-mingled Included Included 10% 2
Household Two-stream Co-mingled Included Included 6% 2
Aluminium cans
Household Sorted on the vehicle Included Included 1% 2
Household Single Stream Co-mingled Included Included 11% 2
Household Two-stream Co-mingled Included Included 5% 2
Other non-ferrous
Household Sorted on the vehicle Included Included 26% 2
Household Single Stream Co-mingled Included Included 73% 2
Household Two-stream Co-mingled Included Included 62% 2
All non-ferrous
Household Sorted on the vehicle Included Included 2% 2
Household Single Stream Co-mingled Included Included 13% 2
Household Two-stream Co-mingled Included Included 10% 2
Metals Household Co-mingled n/a n/a 5.3%36 11
Aluminium Packaging Not defined Uncertain Included 60% - 70% 7
Tin plate Packaging Not defined Uncertain Included 5% - 8% 7
Bio-waste Food waste Household Not defined Included Included 10% - 24%37 1
36 Average level of non-target materials in the output of sorting facilities in England. 37 The figures would appear to include moisture losses.
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Material Waste Steam Collection System Sorting Losses Recycling
Losses Total Reported
Losses Source
Commercial and household
Not defined Included Included aerobic
composting: 1% - 10%
8
Commercial and household
Not defined Included Included anaerobic
digestion: 6% to >10%
9
Packaging Light packaging fraction
Household and similar Road containers Included Not included 24% - 42% 5
Household and similar Road containers Included Not included 18.7% - 35.7% 10
Source:
1. Figures based on 2013 survey of household waste in Denmark. The material loss rates were reported to be the “difference between the collected amount for recycling and the actual recycled amount for different source separated [collection] systems.”
2. Eunomia Research & Consulting, Resource Futures, and HCW Consultants (2011) Kerbside Collections Options: Wales, Report for WRAP, January 2011, www.wrapcymru.org.uk/content/kerbside-collection-options-wales
3. Luca Stramare (2013) managing Post-consumer Plastics Packaging Separate Collection: the COREPLA Experience, presentation at EPR Club / FEAD Seminar on EPR and Packaging, Brussels, 27 June 2013.
4. Extended Producer Responsibility Alliance (2014) The Effects of the Proposed EU Packaging Waste Policy on Waste Management Practice: A Feasibility Study, October 2014, www.expra.eu/downloads/expra_20141004_f_UGGge.pdf, p. 18
5. Gallardo, A., María D., Bovea, Francisco J. Colomer, Míriam Prades, and Mar Carlos (2010) Comparison of Different Collection Systems for Sorted Household Waste in Spain, Waste Management, Vol 30, pp.2430-2433
6. Extended Producer Responsibility Alliance (2014) The Effects of the Proposed EU Packaging Waste Policy on Waste Management Practice: A Feasibility Study, October 2014, www.expra.eu/downloads/expra_20141004_f_UGGge.pdf
7. GVM (2009) Recycling-Bilanz für Verpackungen, Berichtsjahr 2009, Seite 51
8. WRAP (2013) A survey of the UK organics recycling industry in 2012, Report prepared by Urban Mines, August 2013. Range based on response to survey, 58% of respondents reported having contamination levels of less than 1% and 2% said that contamination levels were in excess of 10%.
9. WRAP (2014) A survey of the UK Anaerobic Digestion industry in 2013, Final Report for WRAP prepared by LRS, September 2014, 21% of commercial site respondents reported reject levels of 6-10%, and 25% reporting rejects over 10%.
10. Ecoembes (2007) Estudio para la determinacion de la fórmula de pago de aplicación a la recogida selectiva de envases ligeros (Study to determine the formula of payment of application to the collection of light packaging), September 2007, www.ecoembes.com/sites/default/files/archivos_estudios_idi/estudio_formula_de_pago_ee_ll.pdf
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11. WRAP (2015) Material Facility Reporting Portal: Q3 2015 – Commentary, www.wrap.org.uk/sites/files/wrap/Materials_Facility_reporting_portal_Q3_2015_commentary_0.pdf
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5.5 Industry Specifications on Material Quality
The supply specifications set by industry are a useful starting point for understanding what the quality criteria are for secondary materials. A number of publicly available specifications and reports were reviewed to demonstrate the levels of contamination / non-target materials industry is willing to tolerate within recycling processes. It is important to understand these limits in the context of this work as they determine what the market is likely to accept, although it is clearly stipulated in a number of sources that the ultimate decision about buying or selling materials will depend on the agreements reached between the contracting parties.
As far as possible, information on industry specifications has been obtained for the following materials, with a focus on the grades of material that are likely to arise in the municipal waste stream:
Paper and card;
Metals;
Plastics;
Glass;
Textiles;
Bio-waste; and
Wood.
The full findings are presented in Appendix A.4.0, with details given for each of the above materials. Where available, information was also gathered from international markets to provide a cross comparison of the tolerance thresholds being set by preprocessors based outside of the European Union. This is important because Member States may take the 10% limit to be explicitly condoning collection and/or sorting systems that result in levels of contamination that many reprocessors would not consider acceptable. This section aims to highlight that, for the vast majority of materials, this rate is quite likely to be above the level which many reprocessors would consider acceptable. Thus, any limit set by EU law needs to be seen in light of the calculation rules for achieving the recycling targets and not as a tacit condoning of low quality materials that will not be suitable for European reprocessors. That having been said, the fact that these losses can be included in recycling rates might lead to some gain-saying of the measurement system (more contamination being left in product streams, for example).
The various specifications are set out in different ways and use a range of different terms, described in more detail in Appendix A.4.0. Table 5-2 aims to summarise – as far as is possible given the range of material grades that could potentially be considered and the different methods for measuring and defining input contraries – the key findings from the various specifications that were reviewed. For each of the main material groups Table 5-2 shows the proportion (by weight) of contraries (sometimes referred to as contaminants or non-target materials) that specifications stipulate as being acceptable for the reported material grades.
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Table 5-2: Summary of European Tolerance Levels for Key Municipal/ Household Grades
Material Material Grades % Contraries
by Weight Member States Considered and Source
Paper/Board Old Corrugated Card / News & Pams
0.5% - 1.5% European Standard (EN 643:2014)
Ferrous Metals1 Steel Scrap (UBCs3) 0.4% - 1.5% European Steel Scrap Specification
Non-Ferrous Metals
Aluminium Scrap (UBCs3/ post-consumer packaging)
0% - 5% European Standard (EN 13920: 10/14/15)
Plastic HDPE/PET/film 0% - 8% Germany (Duales System Deutschland), France (Accreditation Eco-emballages), UK (Resource Association)
Glass2 Container cullet 0% - 5% UK – Resource Association
Textiles Household 0% - 5% UK – Resource Association
Wood B and C grades 0% - 1% UK – Resource Association
Bio-wastes Compost and digestate 0% - 0.5% Austria, Belgium, Switzerland, Sweden, Germany, UK – European Compost Network Country Reports
Notes:
1. For Fragmentised scrap from incineration, tolerance level for contraries defined as a minimum Fe content of 92%.
2. Other specifications, including the European End of waste criteria, specify acceptable levels of contraries in terms of ppm (parts per million) rather than % by weight.
3. UBC = Used beverage container.
5.6 Outlining an Approach to Measuring Recycling
An effective measurement method used to define a Member State’s performance against the recycling targets should:
1) Ensure comparability across all Member States (an issue which has been repeatedly raised by numerous stakeholders since the Commission commenced the revision of the waste management targets in 2013); 38 and
2) Enhance the quality of materials supplied to reprocessors.
38 See, for example, Eunomia Research & Consulting, Copenhagen Resource Institute, and Öko-Institut (2014) Impact Assessment on Options Reviewing Targets in the Waste Framework Directive, Landfill Directive and Packaging and Packaging Waste Directive, February 2014, http://ec.europa.eu/environment/waste/pdf/target_review/Targets%20Review%20final%20report.pdf
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The sections below discuss how recycling may be measured in light of the approach suggested in Section 5.1.
5.6.1 Measurement Point
Member States currently report on recycling at various points along the supply chain, making it impossible to directly compare actual levels of recycling performance. Reporting recycling at the point materials enter a final recycling process would allow for greater consistency in how Member States report their performance against the targets. It would also help to ensure that low quality collection systems with high levels of contamination are not inadvertently endorsed by allowing countries simply to report the quantity of material collected for recycling. Instead, it would ensure that collection systems which deliver high quality materials are favored (i.e. materials with limited amounts of non-target / non-recyclable materials). Reporting on inputs to a final recycling process will also remove the possibility of people leaving more contamination in the output fractions of sorting facilities.
Much of the debate surrounding the first legislative proposals put forward in July 2014 revolved around how performance against the targets could be measured for dry recyclables. Very little attention was given to the organic fraction, despite the fact that, in order to achieve the higher municipal waste recycling targets, increasing volumes of biowaste will have to be captured for recycling. It is worth considering each waste stream in turn.
5.6.1.1 Dry Recyclables
Industry appears to support the position that the amount of dry recyclables – or more specifically packaging materials – reported as recycled should be measured as the input to a final recycling process. For example, a recent position statement issued by EUROPEN, and supported by 29 other organisations39, includes the following recommendation in relation to how recycling should be measured:
“Establish a solid, comparable and harmonised calculation method for measuring and reporting national packaging recycling rates that is feasible to implement for all
39 These organisations include: ACE - The Alliance for Beverage Cartons and the Environment, AIM - European Brands Association, A.I.S.E.- The International Association for Soaps, Detergents and Maintenance Products, ARA - Altstoff Recycling Austria AG Packaging Compliance Scheme, Austria, Cosmetics Europe, DSD - Der Grüne Punkt Dual System for Packaging Recycling, Germany, EAA – European Aluminium, Eco-Emballages – Packaging Recovery Organisation, France, EDANA - The International Association Serving the Nonwovens and Related Industries, Elipso - French Plastic and Flexible Packaging Association, EPRO - European Association of Plastics Recycling and Recovery Organisations, European Bioplastics e.V., EXPRA - Extended Producer Responsibility Alliance aisbl, FEA – European Aerosol Federation, FEVE – the European Container Glass Federation, FPE – Flexible Packaging Europe, IK Industrievereinigung Kunststoffverpackungen e.V., INCPEN – The Industry Council for Research on Packaging and the Environment, INTERGRAF - European Federation for Print and Digital Communication, MPE - Metal Packaging Europe, Pack2Go Europe – Europe’s Convenience Food Packaging Association, PlasticsEurope - Association of Plastics Manufacturers, REKOPOL – Recovery Organisation S.A., Poland, Repak – Packaging Recovery Organisation, Ireland, SERVING EUROPE - Branded Food and Beverage Service Chains Association, Sociedade Ponto Verde, S.A. – Packaging Recovery Organisation, Portugal, TIE - Toy Industries of Europe, UNESDA - Union of European Soft Drinks Associations, Valpak - Environmental Compliance, Recycling and Sustainability Solutions, UK
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packaging materials i.e. based on the input into a final recycling process after sorting operations have been completed” 40 (emphasis added).
Paragraph 2(a) of the measurement approach outline in Section 5.1 states that Member States can report the outputs from sorting operations as long as “such output waste is introduced into the final recycling process”. This statement could be interpreted in two different ways for dry recyclables that pass through one or more sorting facilities:41
Either that the outputs from a sorting operation can be reported as having been recycled if, further down the waste management chain, they are sent to a final recycling process; or
That the waste coming from the sorting operation has to be sent directly to a final recycling process in order to be eligible for reporting.
If the latter was the case, then this would rule out reporting from any sorting operation other than the last sorting operation prior to the material being ‘finally recycled’, even if there were good reasons to believe that the amounts disposed of or sent for energy recovery following earlier sorting stages were less than 10%. This would be equivalent to reporting at the input to the final recycling process.
The former interpretation, on the other hand, would mean that the outputs from any sorting process could be included as long as subsequent losses to disposal and energy recovery were less than 10% of the quantity reported. For example, the outputs of a primary sorting facility could be reported even when this material is sent to further secondary and tertiary sorting operations prior to reprocessing, providing that subsequent losses to disposal / energy recovery in all stages prior to final recycling were less than 10%. It is this definition that we have assumed for the purpose of the discussions below. In this case a more precise wording would be that “such output waste is subsequently sent into a final recycling process”.
5.6.1.2 Biowaste
Information gathered as part of the development of the European Reference Model on Municipal Waste Management suggested that, on average, food and garden waste make up 24% and 11% of municipal waste across the EU28, respectively (there is a large variation across countries).42 The achievement of the proposed recycling targets will therefore not be possible without concerted efforts to recycle biowaste.
40 EUROPEN (2015) Circular Economy Package: Joint Cross-industry Packaging Value Chain Recommendations, September 2015, www.europen-packaging.eu/news/news/92-packaging-value-chain-industries-launch-joint-recommendations-for-a-resource-efficient-circular-economy.html 41 Materials which are collected as separate streams may not pass through a sorting process – see discussion in Section Error! Reference source not found. 42 Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission Directorate-General for the Environment and European Environment Agency, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip
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The existing rules governing reporting on municipal recycling rates under the Waste Framework Directive are set out in Commission Decision 2011/753/EU. Article 2(6) of this Decision stipulates that:
“Where the target calculation is applied to the aerobic or anaerobic treatment of biodegradable waste, the input to the aerobic or anaerobic treatment may be counted as recycled where that treatment generates compost or digestate which, following any further necessary reprocessing, is used as a recycled product, material or substance for land treatment resulting in benefit to agriculture or ecological improvement” 43 (emphasis added).
This clause has been used by a number of Member States to declare the weight of the organic-rich output (ORO) fraction from MBT facilities as having been recycled when it is applied to land.
In the absence of end of waste criteria at EU level, a number of Member States have now developed an end-of-waste standard which can be met by ORO (our understanding is that some countries may also be counting ORO as ‘recycled’ without having developed any end-of-waste standards). It should be noted that the end-of-waste criteria set out in Article 6 of the Waste Framework Directive requires that such determinations “will not lead to overall adverse environmental or human health impacts.”44 It is of some interest that widely varying end-of-waste specifications now exist, notably, in respect of which materials may or may not be considered as appropriate inputs in order for the treated waste to be considered to have met quality standards for compost, or digestate. Section 7.2.2 examines the research conducted by the JRC over a number of years and presents some of the concerns associated with applying organic materials that have been extracted from mixed municipal waste to land.
Including the application of ORO to land in a country’s recycling targets has implications in terms of the ease with which recycling can be increased up to a certain level. If one assumes that recycling can be measured at the point where materials are inputted into the biological treatment process the output could be factored up to account for natural moisture and carbon losses that occur as part of the composting process. According to our estimations ORO could potentially allow for recycling rates of between 40% and 50% of the mixed waste fraction to be achieved. The proliferation of a range of end of waste standards, notably, those which include provision for allowing the output from processes for treating mixed waste to be counted towards recycling targets, would tend to make separate collection of biowaste less likely. Already there is evidence of a growing number of Member States starting to rely on ORO to help them achieve their municipal recycling targets. In our view, given the environmental and quality concerns discussed in Section 7.2.2, and in the interests of making performance measurement across countries comparable, one or more EU ‘end of waste’ standards (e.g. for compost and digestion residuals) should be established along the lines proposed by the JRC which excludes mixed municipal waste. Counting the input
43 Commission Decision 2011/753/EU Establishing Rules and Calculation Methods for Verifying Compliance with the Targets set in Article 11(2) of Directive 2008/98/EC of the European Parliament and of the Council, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32011D0753 44 Article 6(1)(d) in the Waste Framework Directive (Directive 2008/98/EC)
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material towards recycling targets only where one of the standards was met will have three distinct advantages:
1) It will support the view that biowaste should be separately collected; 2) It will support quality composting and thereby protect agricultural and other land;
and 3) Improve comparability in recycling rates across Member States.
5.6.2 Final Recycling Process
If recycling is to be measured at the point waste enters a final recycling process it is necessary to clearly define what is meant by this process for both dry recyclables and biowaste. It is not clear why only mechanical sorting has been included in the definition proposed by the Commission and we believe that it is worth explicitly stating that some of the pre-sorting can occur at the facility which houses the final recycling process. The following approach to defining a final recycling process could be considered:
A facility where materials are reprocessed into new products, materials or substances following the completion of all necessary pre-sorting (including sorting of waste materials at the front-end of the recycling process). For biowastes the outputs should comply with relevant European compost and digestate standards.
Given the complexity of the sorting and reprocessing procedures for certain waste streams – for example, plastics, WEEE, and furniture – it may be necessary for the Commission to develop practical guidance to provide clear examples of what constitutes a final recycling process for different materials/products.
The approach suggested by the Commission states that waste exported from the European Union for preparation for reuse or recycling shall only count towards the achievement of the targets if the exporter can prove, in compliance with Regulation (EC) No 1013/2006, that the treatment outside the Union took place under conditions that are equivalent to the requirements of the relevant EU environmental legislation. There is no stipulation about how waste exported for recycling should be measured. The assumption, therefore, appears to be that because the final recycling process is not geographically bound the reporting obligations will apply equally to facilities located outside of the Union, at least when material losses cannot be shown to be less than 10%. As discussed in Section 5.5, the 10% limit may act to stimulate exports to facilities that are able / willing to tolerate higher levels of contraries than recyclers based within the European Union.
5.6.3 Material Losses
Member States can report the weight of the output of any sorting operation as being recycled, provided that material losses remain below 10% of the total weight of the material (it is also stated that losses in weight of materials or substances due to physical and/or chemical transformation processes inherent to the recycling process shall not be considered). Material losses include any materials that are “landfilled or incinerated”. This leaves open the possibility that recovery options other than energy recovery are effectively defined as recycling, even where the recovery activity bears little or no relation to what might be considered to be recycling. This might be a particular issue in some countries for biowastes, where attempts are made to distinguish between ‘recycling’ of biowastes, and other forms of recovery (of lower grade materials). There may be merit in expanding the
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implied list of operations which are effectively included in the 10% loss figure, not least to avoid gain-saying the intent behind the targets. The reference to “the weight of materials or substances that are not targeted either by separate collection or the final recycling process and that are further landfilled or incinerated remains below 10% of the total weight to be reported as recycled” could be revised to “the weight of materials or substances that are not subject to a final recycling process remains below 10% of the amount reported as recycled at the point of reporting.” This would avoid some potential abuse of the current wording and maintain its principal intent.
Assuming that sorting operations from any point in the supply chain are eligible for reporting, it is likely to be in the interest of Member States to report the weight of recycling as close to the point of collection as possible. This minimises the quantity of material that will have been rejected and so the reported weight of recycling, and therefore the calculated recycling rate, will be higher. It may also, potentially, simplify reporting processes, although it should be considered also that various parties within the supply chain operate in structures which do not always encourage accurate reporting.45
There could be a need to specify whether the 10% limit applies to actual amounts of waste, individual facilities, individual material streams or to the totality of municipal/packaging waste. It seems reasonable to assume that for packaging materials, the measurement must be applied at least on a material specific basis since the Directive targets are material specific.
If the 10% limit is meant to be applied separately to each material stream then the point in the chain of operations at which outputs could legitimately be reported whilst respecting the 10% principle is likely to vary by material, and also, by nature of the collection system. For example, separation of steel from other materials is performed relatively effectively by primary sorting facilities, and the sorting is generally ‘positive’ (materials are extracted from a combined stream) so that the level of losses following primary sorting are commonly less than 10% of the output material.46 Therefore, for metals, the weight of the output from the primary sorting facility (or potentially at the point of collection) could, unless the facility was being operated poorly,47 or unless the collected stream was particularly challenging, be reported as the weight recycled under the new proposal.
The studies presented in Appendix A.3.0 show that loss rates for most materials in reasonably well-managed systems are usually below 10%. The clear exceptions to this are in the case of collection of mixed plastics, and glass, where the glass is collected comingled with other materials. The plastics material stream output from a primary sorting facility commonly contains 10-20% (or in some cases higher) of non-target materials and if that was
45 In terms of ‘mechanism design theory’, the existing structures do not always encourage those engaged in the supply chain to report their activity in an accurate manner. This highlights the potential value (albeit this does not necessarily resolve all issues) in systems which track the movement of waste through processes from collection to the final recycling process, as well as at the process itself. 46 A UK study indicated contaminant levels of the order 1-3% for metals (see Enviros Consulting (2009) MRF Quality Assessment Study, Report for WRAP, November 2009). Some other studies suggest higher losses than 10% (e.g. Expra suggests, for metal packaging, a weighted average loss of 14% in recycling). Further details can be found in Appendix A.3.0. 47 For example, operating well over capacity with conveyors significantly overloaded.
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clearly the case, this could not be used as the point of reporting of final recycling (as at least 10% or more of the material will be subsequently lost prior to disposal or energy recovery).48 In this example it is necessary to move further down the supply chain (e.g. to secondary/tertiary sorting facilities) before the weight of the output from sorting operation is eligible for reporting as final recycling. High contamination rates are also observed in the glass material stream outputted from a sorting facility where glass has been collected with other comingled materials, and therefore, as for plastics, the outputs from the primary sorting facility may not be eligible for reporting.
In the case where the 10% limit is to be considered in the aggregate – that is, where the 10% limit applies to municipal waste as a whole – then the point in the sorting chain at which Member States may report the outputs from sorting plants as final recycling would be the same for all materials. In other words, provided that less than 10% by weight of all materials were subsequently disposed of, or treated at energy from waste facilities, outputs from a primary sorting facility could probably be reported, even if loss rates are higher than 10% for specific material streams.
For packaging waste the situation is clearer: recycling targets are defined for separate materials and so the 10% limit would need to apply to each separate material stream to remain concordant with the suggested measurement method. Evidently, there is overlap across these two interpretations: since municipal waste that is recycled will contain packaging, then even if the view was taken that the municipal waste target could be reported at the aggregate level, it might be necessary to report the packaging fractions at a different point in the chain to municipal waste as a whole. The slightly counter-intuitive implications of this would be that recycling of plastics packaging from municipal waste might theoretically contribute a higher tonnage to municipal waste recycling than it does to packaging waste recycling.
Given the variation in loss rates across materials, the limitations imposed by using a single limit for all materials need to be understood. It can be seen from some of the studies reported in Appendix A.3.0 that material loss rates for some materials, particularly for those separated out at source, can be below 10%, whilst final recyclers of many materials would not deem material with contamination rates as high as 10% remotely acceptable. Thus, setting material specific limits would, in Eunomia’s view, offer a more tailored approach that could more accurately reflect the nature of the materials, and the current operational realities of collection and sorting infrastructure, as well as the demands of the reprocessors.
In order to encourage improvements in collection and sorting infrastructure it would be necessary to ensure that the limits are realistic in the short to medium-term. It is worth bearing in mind that the first time Member States will have to achieve a target using the new calculation method will be in 2025, although reporting in this manner will have to start before this date.49
Given the reasonable input specification of reprocessors and formal standards where they exist (e.g. EN643 for Paper) (detailed in Section 5.5) a 10% loss of material would allow
48 Enviros Consulting (2009) MRF Quality Assessment Study, Report for WRAP, November 2009 49 See Table 3-1 in Section 3.0 of Appendix A.1.0.
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collected material (or material from the first sorting process) to be considered as ‘recycled’ even where it was contaminated beyond the levels that most EU reprocessors would tolerate. A 5% threshold still exceeds the input specifications for all materials, except plastics, and is likely to mean the majority of reasonably designed and operated collection systems would be able to use the derogation.
Based on the review of publicly available data presented in Appendix A.3.0 and A.4.0 it may be more appropriate to set material specific limits such as those set out in Table 5-3. These limits may help to ensure that efforts continue to be made to improve the quality of materials being collected and to avoid materials being exported abroad, because, for example, foreign facilities might tolerate higher levels of contrary materials or will be able to remove them at lower cost. The levels set out in Table 5-3 are in line with those suggested in research conducted on behalf of EUROPEN:
“A potential alternative approach to this might be to add a clear definition of what constitutes “impurities” before changing the 2% threshold for impurities to a more feasible level achievable by all material fractions (in the range of 5% - 10%).50
Table 5-3: Possible Material Specific Limits for Reporting Against the Municipal and Packaging Waste Recycling Targets
Relevant Material Maximum Allowable Limit of Material Losses as a Proportion of the Total
Amount of Waste Reported as Having Been Recycled
Plastics 10%
Non-ferrous metal 5%
Ferrous metal 5%
Glass 5%
Paper & Card 5%
Food waste 5%
Other bio-waste 5%
Wood 10%
Other waste streams 10%
5.6.4 Summary
Possible elements to specify the measurement method include the following (a visual representation of the measurement method is provided in Figure 5-7):
1) For the purpose of calculating whether the targets have been achieved, a) for each Relevant Material the weight of the waste "recycled" shall be
understood as the weight of the input waste entering a Final Recycling Process;
50 Cyclos and HTP (2014) Impact Assessment: The European Commission’s Proposed Changes to the Calculation Method for National Packaging Recycling Rates (Executive Summary), Report for EUROPEN, October 2014, www.europen-packaging.eu/library/publications/11-guides/227-europens-impact-assessment-the-european-commissionas-proposed-changes-to-the-calculation-method-for-national-packaging-recycling-rates.html , p. 9
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b) the weight of the waste "prepared for reuse" shall be understood as the weight of the waste that has effectively undergone all necessary checking, cleaning and repairing operations to enable reuse without further sorting or pre-processing.
2) By way of derogation from Paragraph 1, the weight of the output of any sorting operation may be reported as the weight of the waste “recycled” provided that:
a) such output waste is subsequently sent into a Final Recycling Process; b) for each Relevant Material the weight of materials or substances that are
not subject to a Final Recycling Process remains below the figures in Table 5-3, as a percentage of the total weight to be reported as recycled. Losses in weight of materials or substances due to physical and/or chemical transformation processes inherent to the Final Recycling Process shall not be considered. Moisture loses from the drying of biowaste between the point of collection and the Final Recycling Process shall also be excluded. For the avoidance of doubt, losses from sorting systems are to be considered, including all sorting prior to the point at which the Final Recycling Process occurs.
The following definitions shall apply in relation to the above:
A Final Recycling Process – as per the definition provided in Section 5.6.2 above.
Relevant Material shall be construed to be the following separate material categories: plastics; non-ferrous metal; ferrous metal; glass; paper & card; food waste; other bio-waste; and wood waste. ‘Other waste streams’ shall also be considered as a Relevant Material and includes all other materials arising in the municipal waste streams which have not already been listed.
Separate Collection shall take the same meaning as that given in the Waste Framework Directive, where it is taken to mean “collection where a waste stream is kept separately by type and nature so as to facilitate a specific treatment.”51
51 Article 3(11)
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Figure 5-7: Measuring Recycling Performance
Key
Thermal recovery
Landfill
First sorting / treatment facility
Final Recycling Processand / orWaste Prepared for Reuse
Municipal and/or packaging waste
sorting / process contraries sent for recycling
Mixed waste stream collected for recycling
Secondary sorting Material flows
Final Recycling Processand / orWaste Prepared for Reuse
Waste stream collected separately and kept separate
Bulking / rudimentary sorting
'Material Losses'
sorting / process rejects sent for disposal or
thermal recovery
'End Destination' of Waste Materials
Point of Measurement under Paragraph 1
Point of Measurement under Paragraph 2 (i.e. Derogation)
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6.0 Reuse Targets
As required by the project’s Terms of Reference, some of the work presented in this section was undertaken prior to the publication of the revised legislative proposal in December 2015. The analysis presented below, therefore, does not always consider the implications of the new legislative proposals.
This Section of the report examines the scope for setting reuse targets and how these may be included with the existing preparation for reuse / recycling targets to create a combined target. This is done through the following sub-sections:
Section 6.1 – provides a brief background to why a reuse target should be considered and the different ways in which it may be integrated with the proposed preparation for reuse / recycling targets;
Section 6.2 – summarises the feedback received as part of the Commission’s Member State consultation which was held over the summer of 2015;
Section 6.3 – compiles data on the reuse of packaging materials and items that are likely to arise in the municipal waste stream at the end of their life; and
Section 6.4 – takes the available data and aims to understand it in the context of the impact it may have in terms of enabling Member States to more readily achieve the targets set out in the Commission’s supplement to the impact assessment. A number of recommendations are made as to how reuse may best be included as part of a combined target.
6.1 Background
Consideration of the appropriate means for inclusion of ‘reuse’ in waste targets, as with preparation for reuse, reflects the Commission’s objective to see materials being moved up the waste hierarchy. Whilst the existing target in the waste Framework Directive focuses on quantities of waste recycled and prepared for reuse, this does not take into account the many reused products and materials that never enter the waste stream. Reuse is one element of waste prevention, so some stakeholders have argued for setting a broader waste prevention target (e.g. total waste arisings per capita, or total packaging waste generated per capita).
A number of Member States are keen to see a way in which progress to support reuse could be recognised as contributing towards the MSW and/or packaging waste recycling / preparation for reuse targets. Some also believe that there is a possibility that Member States who strongly promote reuse may find it harder to achieve high recycling targets.
There are ultimately three broad options when considering setting a reuse target in conjunction with the proposed preparation for reuse and recycling targets (Figure 6-1):
1) Three targets – keep the targets separate in order to explicitly represent each tier of the hierarchy;
2) Two targets – here one could either keep the current preparation for reuse and recycling targets combined, but include a separate reuse target, or have a separate
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recycling target and combine preparation for reuse and reuse into a single target; and
3) One target – combine all three elements within a single target.
Figure 6-1: Options for Setting Reuse, Preparation for Reuse and Recycling Targets
There are positive and negative attributes to each of the options listed above. It is worth examining some of the key elements for and against the different approaches.
Three separate targets – separating out each of the targets has the advantage of ensuring that each tier of the waste hierarchy is explicitly represented. For example, because the preparation for reuse and recycling targets are currently combined in the Waste Framework Directive, it is not uncommon for recycling to take preference, with less regard being given to preparing items for reuse (which requires more careful collection of products, and appropriate storage/handling etc.). It is for this reason that organisations such as RREUSE have recommended that separate quantitative targets are needed for preparation for reuse.52 A challenge to setting individual targets, however, is that it can be difficult to define what an appropriate and fair level of ambition is for each of the targets across all Member States. Member States would, however, be required to focus on all three areas in the upper tiers of the hierarchy, rather than relying on recycling – which is at the lowest tier of the three options – to meet the bulk of a combined target.
52 RREUSE (2015) Putting Reuse and Repair at the Heart of the EU’s Circular Economy Package, March 2015, www.rreuse.org/putting-reuse-and-repair-at-the-heart-of-circular-economy-legislation/
OR
Reuse Target
Preperation for Reuse Target
Recycling Target
Three Targets
Reuse Target
Preperation for Reuse Target+
Recycling Target
Two Targets
Reuse Target+
Preperation for Reuse Target+
Recycling Target
One Target
Reuse Target+
Preperation for Reuse Target
Recycling Target
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The current weight based targets rely on having data for both a numerator (e.g. amount of material recycled and/or prepared for reuse) and a denominator (total waste generated). A clear challenge in setting a reuse target would be that it might be difficult to define an appropriate denominator if the intention was to target a ‘reuse rate’. Given that reused products and materials never become ‘waste’, using ‘waste generated’ does not seem appropriate. It might be more appropriate to consider sale of reused goods / products as a proportion of total sales, but this would, most likely, need to refer to specific product streams (or a narrow range of these).
Another possibility would be to consider the total amount of a product in use in any given year. Estimating this figure for each of the 28 Member States would not be a straightforward task, as it would require an understanding of how much of a given product has been placed on the market in the past and the average lifespan of the products concerned (the Commission has recently undertaken such a task in relation to EEE to estimate the likely arisings of WEEE in any given year).53 This may be one possible approach, but it would be very challenging to develop a consistent and robust approach for each Member State, and there might be a need for product specific targets.
A way around this would be to set different types of reuse targets. For example, Flanders has set a target of reusing 5 kg of material per person by 2015 (although it is not clear if this is strictly a reuse or preparation for reuse target).54,55 As part of the French Extended Producer Responsibility (EPR) scheme for furniture, a target has been set to “increase the amount of used furniture put back on the market by social enterprises by 50% over a 4-year period in comparison to a baseline situation.” This also seems to refer to preparation for reuse, rather than reuse, although the boundaries in this regard can be blurred. Nevertheless, a similar type of target may be set which encompasses reuse, for instance, by defining quantitative objectives for increasing the amount of material being sold by second hand shops or via online portals such as eBay. However, given that this activity falls outside of the definition of waste, it would be much harder to monitor in a consistent and comparable manner.
Two targets – there are two options here: either reuse can be considered in isolation, with preparation for reuse / recycling forming a separate target, or reuse and preparation for reuse could be combined and the recycling target kept
53 United Nations University, Statistics Netherlands, Bio Intelligence Services, and Regional Environmental Centre (2015) Study on Collection Rates of Waste Electrical and Electronic Equipment (WEEE): Possible Measures to be Initiated by the Commission as Required by Article 7(4), 7(5), 7(6) and 7(7) of Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE), Report for European Commission, October 2015 54 RREUSE (2015) Putting Reuse and Repair at the Heart of the EU’s Circular Economy Package, March 2015, www.rreuse.org/putting-reuse-and-repair-at-the-heart-of-circular-economy-legislation/, p. 4 55 Bio Intelligence Service, Copenhagen Resource Institure, and Regional Environmental Centre (2009) Best Practice Factsheets in Preparation for ‘Waste Prevention Guidelines’: Kringloop Reuse Centres (Flanders), June 2009, http://ec.europa.eu/environment/waste/prevention/pdf/Kringloop%20Reuse%20Centres_Factsheet.pdf
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separate. The latter option makes sense given the blurred line between reuse and preparation for reuse and it could allow for an alternative type of target to be set, for example, the amount of material prepared for reuse and reused per capita.
Having a separate reuse target that sits alongside a combined preparation for reuse / recycling target (as already exists in the Waste Framework Directive and is being considered within the new legislative proposal for the Packaging Waste Directive) means that reuse can be targeted separately. Given the lack of data on reuse and the likely methods that will be required to obtain these data – for example, by indirect means such as surveys – Member States could potentially manipulate the reuse data in their favour if they are reporting under a situation in which all the targets were combined together. By keeping the reuse target separate it will allow time for a standardised measurement method to be developed and reporting to be harmonised.
Single combined target – the simplest way in which reuse could be included in the preparation for reuse / recycling formula would be as follows:
𝑤𝑒𝑖𝑔ℎ𝑡 𝑜𝑓 𝑤𝑎𝑠𝑡𝑒 𝑝𝑟𝑒𝑝𝑎𝑟𝑒𝑑 𝑓𝑜𝑟 𝑟𝑒𝑢𝑠𝑒+𝑤𝑒𝑖𝑔ℎ𝑡 𝑜𝑓 𝑤𝑎𝑠𝑡𝑒 𝑟𝑒𝑐𝑦𝑐𝑙𝑒𝑑+𝑤𝑒𝑖𝑔ℎ𝑡 𝑜𝑓 𝑤𝑎𝑠𝑡𝑒 𝑟𝑒𝑢𝑠𝑒𝑑
𝑡𝑜𝑡𝑎𝑙 𝑤𝑎𝑠𝑡𝑒 𝑔𝑒𝑛𝑒𝑟𝑎𝑡𝑒𝑑+𝑤𝑒𝑖𝑔ℎ𝑡 𝑜𝑓 𝑤𝑎𝑠𝑡𝑒 𝑟𝑒𝑢𝑠𝑒𝑑
Equation 1
It is evident from this formula that the ‘weight of waste reused’ is included in both the numerator and the denominator. This calculation method acts in such a way that reuse always exerts a positive effect on the calculated rates relative to the rates for only recycling and preparation for reuse. The overall benefit that reuse will have on a combined target is also closely linked to the amount of reuse that is occurring relative to the total amount of waste that is being generated as shown in Table 6-1 and Figure 6-2. It is clear that if there is a large amount of reuse occurring relative to the volume of waste being generated, then a combined target may require that a more ambitious target be set if Member States are to be encouraged to continue making efforts to improve recycling and preparation for reuse. Figure 6-2 shows graphically how the inclusion of reuse has a marked impact on a combined target up to the point at which the amount of reuse is 150%–200% of the amount of waste being generated. Higher levels of reuse, although beneficial, result in diminishing returns in terms of increasing the combined rate of reuse, preparation for reuse and recycling.
The above discussion of three possible options shows that there is no obvious ‘best’ approach. The rest of this Chapter examines the opportunities and challenges of developing a combined target.
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Table 6-1: Combined Reuse/Recycling Targets Calculated for Different Recycling Rates Based on Varying Ratios between Waste Generation and the Amount of Reuse
Amount of Reuse as a Proportion of Total Waste Generated
Recycling Rate
10% 15% 20% 25% 30% 35% 40% 45% 50% 55% 60% 65% 70% 75% 80% 85% 90%
Combined reuse/recycling rates are shown below - these are based on the above recycling rates and the associated ratio of waste generation to reuse
500% 85% 86% 87% 88% 88% 89% 90% 91% 92% 93% 93% 94% 95% 96% 97% 98% 98%
475% 84% 85% 86% 87% 88% 89% 90% 90% 91% 92% 93% 94% 95% 96% 97% 97% 98%
450% 84% 85% 85% 86% 87% 88% 89% 90% 91% 92% 93% 94% 95% 95% 96% 97% 98%
425% 83% 84% 85% 86% 87% 88% 89% 90% 90% 91% 92% 93% 94% 95% 96% 97% 98%
400% 82% 83% 84% 85% 86% 87% 88% 89% 90% 91% 92% 93% 94% 95% 96% 97% 98%
375% 81% 82% 83% 84% 85% 86% 87% 88% 89% 91% 92% 93% 94% 95% 96% 97% 98%
350% 80% 81% 82% 83% 84% 86% 87% 88% 89% 90% 91% 92% 93% 94% 96% 97% 98%
325% 79% 80% 81% 82% 84% 85% 86% 87% 88% 89% 91% 92% 93% 94% 95% 96% 98%
300% 78% 79% 80% 81% 83% 84% 85% 86% 88% 89% 90% 91% 93% 94% 95% 96% 98%
275% 76% 77% 79% 80% 81% 83% 84% 85% 87% 88% 89% 91% 92% 93% 95% 96% 97%
250% 74% 76% 77% 79% 80% 81% 83% 84% 86% 87% 89% 90% 91% 93% 94% 96% 97%
225% 72% 74% 75% 77% 78% 80% 82% 83% 85% 86% 88% 89% 91% 92% 94% 95% 97%
200% 70% 72% 73% 75% 77% 78% 80% 82% 83% 85% 87% 88% 90% 92% 93% 95% 97%
175% 67% 69% 71% 73% 75% 76% 78% 80% 82% 84% 85% 87% 89% 91% 93% 95% 96%
150% 64% 66% 68% 70% 72% 74% 76% 78% 80% 82% 84% 86% 88% 90% 92% 94% 96%
125% 60% 62% 64% 67% 69% 71% 73% 76% 78% 80% 82% 84% 87% 89% 91% 93% 96%
100% 55% 58% 60% 63% 65% 68% 70% 73% 75% 78% 80% 83% 85% 88% 90% 93% 95%
75% 49% 51% 54% 57% 60% 63% 66% 69% 71% 74% 77% 80% 83% 86% 89% 91% 94%
50% 40% 43% 47% 50% 53% 57% 60% 63% 67% 70% 73% 77% 80% 83% 87% 90% 93%
25% 28% 32% 36% 40% 44% 48% 52% 56% 60% 64% 68% 72% 76% 80% 84% 88% 92%
0% 10% 15% 20% 25% 30% 35% 40% 45% 50% 55% 60% 65% 70% 75% 80% 85% 90%
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Figure 6-2: Visual Representation of Combined Reuse / Recycling Targets Calculated for Different Recycling Rates Based on Varying Ratios between Waste Generation and the Amount of Reuse
10%
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Amount of Reuse as a Proportion of the Total Amount of a Waste Stream Generated
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6.2 Member State Consultation
Member States were consulted directly via means of a short questionnaire which was issued by the European Commission in July 2015.56 This questionnaire included the following three questions:
1) Would you agree that additional actions are needed to favour reuse? If yes, what actions do you see as most appropriate at EU level?
2) What would be the key waste streams for which it would make sense to incentive reuse? Are national data available on these streams? If yes, please provide recent statistics on the reuse streams in your Member State.
3) In your view, should reuse streams for which reliable data is available be accounted for and rewarded under the existing recycling and preparation for reuse targets?
Of the 20 Member States that responded to the consultation, all of them felt that additional action should be taken to promote reuse. However, only seven Member States felt that this action should include the setting of reuse targets. Of the seven countries, five stated that the reuse target should be included in the preparation for reuse / recycling targets, whilst two felt that the target should be kept separate noting that a reuse target should be set by a progressive roadmap depending on the level of each Member State. Ten Member States stated that no reuse target should be set because reuse occurs before materials become waste and so is very difficult to quantify.
As part of the consultation Member States were asked to identify key waste streams for which it would make sense to incentivise reuse. Respondents identified one or more materials and these are presented in Table 6-2. It can be seen that electrical and electronic equipment (EEE), listed by a total of 13 Member States, was the most frequently cited product group for it was thought action on reuse should be taken. This was followed closely by textiles and furniture, which were identified by 11 and 10 Member States respectively. Two countries reported that ‘bulky waste’ should be prioritised, but it was not clear if this referred to EEE, furniture, or both. This would lend further weight to the importance of focusing on EEE and furniture. Packaging materials were also thought to represent an area where greater efforts could be made to promote reuse (six countries referred to packaging waste more generally, two specifically mentioned glass bottles, whilst wooden pallets and plastic bottles were each cited once).
Table 6-2: Priority Materials / Products Requiring Action on Reuse
Material / Products Number of Times Material/Product
Identified by Member States
Electrical and electronic equipment (EEE) 13
Textiles 11
Furniture 10
Packaging materials 6
Construction materials (e.g. doors, windows and other items) 5
56 European Commission (2015) Consultation of Member States on the Circular Economy, Responses Received back by 10th September 2015
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Material / Products Number of Times Material/Product
Identified by Member States
Toys 3
Bulky waste (not defined) 2
Books 2
Glass bottles 2
Vehicles (and parts thereof) 2
Dishes 1
Wooden pallets 1
Plastic bottles 1
Medical equipment 1
Copying equipment 1
Tyres 1
Mineral oils 1
Laboratory equipment 1
Kitchen ware 1
6.3 Data on Reuse
Given the lack of focus on reuse until recently and the difficulty of obtaining the information, there is very little data available on reuse. Where data is available, there are issues with respect to the fact that it is collected in very different ways and often covers different products and reuse channels (e.g. reuse via second hand shops, reuse via car boot sales, and reuse via online platforms). We present here data which was provided by Member States or obtained via a search of publicly available reports.
6.3.1 Packaging Waste
The extent of reuse of packaging is significant, although reusable packaging systems are not generally highlighted in a prominent way as part of the public debate. Various studies demonstrate the importance of reusable packaging in the retail chain. Very few countries, however, have official data on their reusable packaging and very few Member States report voluntarily on reusable packaging under the Packaging Directive.
Of the Member States which responded to the consultation, only three reported that they regularly collected data at the national level on the reuse of certain materials / products. In addition, only Denmark, Finland and Luxembourg regularly report to Eurostat on the amount of packaging reused within their national boundaries (Luxembourg also only reports on the reuse of beverage containers). If this reporting behaviour accurately reflects the availability of data (and that is not necessarily the case), then it may be that very little data on the amount of reuse taking place is currently being collected on an official basis by Member States.
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Table 6-3: Data on Reuse of Packaging Waste in Finland (2013)
Material Tonnage of Packaging Reused
Paper/Board 19,510
Plastic 243,804
Glass 28,747
Metal 519,341
Wood 250,706
Total 1,054,108
Source: Finnish Packaging Recycling RINKI Ltd
It was reported that in the Danish packaging statistics reuse only applies to packaging materials that move between two or more companies / enterprises. The only exception to this is when a grocery wholesaler also owns the retail stores and ships products to and from the stores using reusable crates and other packaging units. It was also noted that shipping containers are not included in the statistics. If they were to be included, this would significantly increase the amount of steel packaging that would be considered a part of the reuse cycle.
Table 6-4: Data on Reuse of Packaging Waste in Denmark (2013)
Material Type Product
Number of Uses per
Year (thousands)
Trips Per
Year
Number of Units in
Circulation per Annum (thousands)
Weight per Unit (kg)
Annual Consumpti
on (thousand
tonnes)
Glass Bottles Beer 285,930 5 57,186 0.30 85.8
Glass Bottles Soft drinks 136,663 5 27,333 0.20 27.3
Plastic Bottles Soft drinks 89,573 5 17,915 0.065 5.8
Plastic Crates Beer/Soft drinks 16,904 6 3,381 2 33.8
Plastic Trays Beer/Soft drinks 985 10 118 4 3.9
Metal Kegs Beer 1,300 10 156 10 13.0
Plastic Pallets Food 3,400 7 486 3 10.2
Wood Pallets All 20,000 5 4,000 25 500.0
Plastic Crates Distribution 45,000 30 1,500 2 90.0
Wood Cable
drums Diverse 10 1 10 100 1.0
Metal Vessels Food 150 10 15 50 7.5
Metal / Plastic
Drums / containers
Diverse 300 3 100 50 15.0
Metal Cylinders Gas 2,500 4 750 10 25.0
Metal Roll
containers Food 1,800 50 36 20 36.0
Metal Butchers
hooks Meat 16,000 12 1,600 1 16.0
Total 620,515 114,585 870
Source: Danish Ministry of Environment and Food
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The Belgian Interregional Packaging Commission (IRPC) has published data on the reuse of beverage packaging by Fost Plus members (Figure 6-3) and the reuse of industrial and commercial packaging by Val-I-Pac members (Figure 6-4).57 Efforts were made to obtain the raw data but this could not be secured in time for the delivery of the final report.
Figure 6-3: Changes in Reusable Drink Packaging in Belgium Over the Period 2000-2013, All Fost Plus Member (kg)
Source: Belgian Interregional Packaging Commission (2015) IRPC Activity Report 2014, www.ivcie.be/admin/upload/page/file/564.pdf
Figure 6-4: Changes in Reusable Commercial and Industrial Packaging in Belgium Over the Period 2003-2013, All Val-I-Pac Members (tonnes)
Source: Belgian Interregional Packaging Commission (2015) IRPC Activity Report 2014, www.ivcie.be/admin/upload/page/file/564.pdf
Data on the amount of refillable containers placed on the market in five member states – that is, Austria, France, Germany, Italy and Sweden – was extracted from the Canadean
57 Belgian Interregional Packaging Commission (2015) IRPC Activity Report 2014, www.ivcie.be/admin/upload/page/file/564.pdf
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database for 2012.58 The Canadean data provides details on the number of refillable packaging units sold in each county. This figure was multiplied by the average weight of each item (based largely on the weights provided by Denmark in Table 6-4) to derive an estimate of the total weight of refillable packaging placed on the market. This can be considered to be equivalent to the amount of packaging reused in 2012.
Table 6-5: Quantity of Refillable Packaging Reused in Five Member States (2012)
Pack Material
Pack Type Super
Category
Average weight
(kg)1
Austria France Germany Italy Sweden
Million Units Sold2
Glass Bottle Beer & Cider 0.30 872 176 13,057 142 122
Glass Bottle Soft Drinks 0.20 349 532 6,316 2,115 202
Glass Bottle Wines 0.50 201 4 0 0 0
Plastic PET Bottle Soft Drinks 0.065 8 0 5,585 0 35
Plastic PET Bottle Wines 0.065 0 0 0 0 1
Metal Keg Soft Drinks / Beer & Cider
10 5 18 40 8 1
Total Number of Units 1,434 731 24,999 2,265 362
Pack Material
Pack Type Super
Category
Average weight
(kg)1
Weight of Refillable Packaging Sold (thousand tonnes)3
Glass Bottle Beer & Cider 0.30 262 53 3,917 43 37
Glass Bottle Soft Drinks 0.20 70 106 1,263 423 40
Glass Bottle Wines 0.50 100 2 0 0 0
Plastic PET Bottle Soft Drinks 0.065 1 0 363 0 2
Plastic PET Bottle Wines 0.065 0 0 0 0 0
Metal Keg Soft Drinks / Beer & Cider
10 48 183 399 84 10
Total Weight Reused 480 344 5,942 549 89
Notes:
1. Average weight of refillable beverage containers, other than wine bottles, was taken from the data provided by Finland in Table 6-4. The average weight of glass wine bottles was obtained from WRAP (2008) Bulk Shipping of Wine and its Implications for Product Quality, Final Report: GlassRite: Wine, May 2008, www.wrap.org.uk/downloads/Bulk_shipping_wine_quality_May_08.1be9881a.5386.pdf
2. Canadean data, www.canadean.com.
3. Weight of refillable packaging sold was calculated by multiplying the number of units sold by the average weight for each unit.
58 www.canadean.com
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6.3.2 Municipal Waste
Data on the reuse of household products or materials that could be construed as being derived from household sources are very limited. From the few examples presented below it is clear that very different approaches have been taken and that they have focused on varying products and/or product categories.
ADEME has produced a number of studies tracking the amount of material being prepared for reuse and reused within France. As part of its most recent report, published in October 2014, the organisation estimated the amount of material to have been reused via a number of online exchange platforms.59 According to its analysis, a total of 1.347 million tonnes of material was sold for reuse in 2013 across three key online platforms and a number of other sites offering free advertisements (Figure 6-5). It is not clear to what extent this material was diverted directly from the municipal waste stream or from other streams. However, it clearly shows the potential scale of reuse that is occurring via online exchange platforms and if one were to extend the focus to other areas of the economy the figure would likely increase markedly.
Figure 6-5: Quantities of Material Sold for Reuse via French Online Platforms (2013)
thousand tonnes
%
Source: ADEME (2014) Panorama de la Deuxieme vie des Produits en France, October 2014, www.ademe.fr/sites/default/files/assets/documents/panorama-de-la-2eme-vie-des-produits-reemploi-synthese-2014_3.pdf, p. 260
Based on the data presented in Figure 6-5 ADEME provides a proportional breakdown by material stream for products which were sold via eBay or Le Bon Coin. These proportions allowed for the tonnages presented in Table 6-6. From this it can be seen that the greatest volume of reuse was derived from textiles, books/CDs/DVDs, and leisure equipment.
59 ADEME (2014) Panorama de la Deuxieme vie des Produits en France, October 2014, www.ademe.fr/sites/default/files/assets/documents/panorama-de-la-2eme-vie-des-produits-reemploi-synthese-2014_3.pdf
824183
183
157
Le Bon Coin
PriceMinster
eBay
Other free advertisement sites 61%14%
14%
12%Le Bon Coin
PriceMinster
eBay
Other free advertisement sites
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Table 6-6: Quantities of Different Products Reused via Le Bon Coin and eBay (2013)
Product Category Products Amount Sold for Reuse (thousand
tonnes) Exchange Platforms
Electrical and electronic equipment
Large and small appliances, screens, audio-visual equipment, computers
103 le Bon Coin, eBay
Textiles Clothing, leather goods, linen, shoes 284 le Bon Coin, eBay
Furniture Tables, wardrobes, chairs 82 le Bon Coin
Leisure equipment Games and toys, musical instruments, sports equipment, cycles
114 le Bon Coin, eBay
Books, cassettes, CDs, DVDs
Books, Cassettes, CDs, DVDs 222 le Bon Coin, eBay
Tools DIY, gardening 58 le Bon Coin, eBay
Other Childcare, paramedic (e.g. wheelchair), misc.
41 le Bon Coin, eBay
Trinkets, decoration, etc.
Trinkets, decoration, etc. 92 le Bon Coin, eBay
Source: data derived from figures reported in ADEME (2014) Panorama de la Deuxieme vie des Produits en France, October 2014, www.ademe.fr/sites/default/files/assets/documents/panorama-de-la-2eme-vie-des-produits-reemploi-synthese-2014_3.pdf, p. 260
In the United Kingdom, WRAP has commissioned a number of studies which investigated the amount of reuse occurring within the economy. In 2011, for example, WRAP published a report which – in a similar vein to the ADEME study – sought to quantify the amount of products within 12 product categories that was reused through four online platforms: eBay, Preloved, Gumtree, and Freegle.60 The authors of the report identified a number of challenges associated with making the estimations, which required a very labour intensive process of monitoring each of the websites over a set period of time and then scaling up the results to provide an estimate of the possible tonnage that may be exchanged for reuse in 2011. The data for the 12 product categories are presented in Table 6-7 (these figures are an estimate of the total quantity of products that were actually exchanged in 2011). It can be seen that the quantities presented here are far smaller than those cited by the ADEME study, which covered a far broader range of products.
60 Resource Futures (2011) Online Exchange Potential Impact, Report for Waste & Resources Action Programme, November 2011, www.wrap.org.uk/sites/files/wrap/Online_exchange_FINAL_report.pdf
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Table 6-7: Estimated Weight of Products Exchanged via Four Online Portals (2011)
Product eBay Preloved Gumtree Freegle Total
tonnes reused in 2011
Sofa 4,130 338 8,482 110 13,060
Dining table 2,578 178 2,901 15 5,672
Office desk 163 43 1,340 100 1,646
Office chair 264 18 241 9 532
TV 2,469 105 6,256 38 8,868
Mobile phone 415 12 387 0 814
Computers 202 14 1,055 19 1,290
Other IT 1,603 41 1,016 101 2,761
Washing machine 3,089 169 5,987 300 9,545
Leather jacket 245 8 14 0 267
Cotton shirt 69 0 5 0 74
Jumper 210 1 2 0 213
Total for priority items 15,437 927 27,686 692 44,742
Source: Resource Futures (2011) Online Exchange Potential Impact, Report for Waste & Resources Action Programme, November 2011, www.wrap.org.uk/sites/files/wrap/Online_exchange_FINAL_report.pdf
WRAP has undertaken a number of studies on textile flows within the United Kingdom. One of these studies, undertaken by Oakdene Hollins, estimated that 561,000 tonnes of household textiles were prepared for reuse or reused in 2010 (Table 6-8). The study includes textiles collected by or on behalf of municipalities, which means that these materials would have officially entered the waste stream and then subsequently been prepared for reuse. The quantity prepared for reuse appears to have amounted to 246,600 in 2010. That is, if one assumes the sum of ‘textiles reused in the UK’ and ‘textiles exported for reuse’ in Table 6-8 to have been collected by local authorities, the remaining 314,400 tonnes shown in Table 6-8 would appear to be direct reuse where textiles are sold via charity shops, exchanged online, or given away. Oakdene Hollins’ report notes that:
“Of the 660,000 tonnes which are collected for reuse and recycling, 94% is mixed clothing, shoes and household textile, with a slim proportion of carpets and mattresses. An additional 120,000 tonnes is reused, albeit bypassing any third party collection system, and being directly exchanged or sold by the owner.”61
The authors of the report note that there are some substantial limitations with the data and provide a number of caveats. Nevertheless, the data presented in Table 6-8 provides a useful indication of the likely extent of reuse within the United Kingdom.
61 Oakdene Hollins Research & Consulting (2012) Textiles Flow and Market Development Opportunities in the UK, Report for Wrap, September 2012, p. 19
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Table 6-8: Tonnage of Textiles Prepared for Reuse and Reused in the United Kingdom (2010)
Source of Reuse Preparation for Reuse / Reuse Tonnage
Textiles Reused in the UK Preparation for Reuse
8,700
Textiles Exported for Reuse 237,900
Sub-total 246,600
Textiles Sold via UK Charity Shops
Reuse
192,400
Online Exchange 3,000
Given Away 119,000
Sub-total 314,400
Total 561,000
Source: Table 2 in Oakdene Hollins Research & Consulting (2012) Textiles Flow and Market Development Opportunities in the UK, Report for Wrap, September 2012, p. 18
Research published by the United Kingdom’s Department for Environment, Food and Rural Affairs (Defra) has estimated the amount of furniture reused via various channels in England in 2012. These data are presented in Table 6-9, from which it can be seen that 229,000 tonnes were estimated to have been reused – this figure would likely be somewhat higher if it was extended to Wales, Scotland and Northern Ireland.
Table 6-9: Tonnage of Furniture Reused in England (2012)
Source of Reuse Domestic Furniture
Commercial Furniture
Total Confidence in Data
Furniture Reuse Organisations 54,000 2,000 56,000 Medium
Charity Shops 35,000 n/a 35,000 Medium
Online Exchange 16,000 1,000 17,000 Medium
Commercial Second Hand Shops 36,000 6,000 42,000 Low
Other Commercial Reuse Channels n/a 8,000 8,000 Low
Car Boot Sales 8,000 n/a 16,000 Medium
Informal Giving 80,000 n/a 80,000 Low
Total 229,000 18,000 247,000 Low1
Note:
1. Low confidence of key aspects of pathway data
Source: Table 4 in Resource Futures (2012) The Market Potential and Demand for Product Reuse, Product Module: Furniture, Report for Department for Environment, Food and Rural Affairs, November 2012, p. 3
The French PRO scheme for clothing, ECO TLC, reports that 120,431 tonnes of textiles were collected and processed in 2014 (up from 114,705 tonnes in 2013). Of this 65% was reused (78,280 tonnes).62 Of the clothing that was reused, 6,022 tonnes was deemed to be of ‘first grade’ quality, while the vast majority, 61,420 tonnes, was reported to comprise of lower grade materials. The remaining 6,022 tonnes was related to the reuse of shoes.
France’s EPR scheme for furniture (Eco-mobilier for domestic furniture and Valdelia for professional furniture) set a reuse target, in the form of increasing the amount of used
62 EC TLC (Undated) L’Essentiel 2014, www.ecotlc.fr/page-41-a-propos-d-eco-tlc.html, p. 10
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furniture put back on the market by 50% from a baseline by 2017. The law grants social enterprises access to collection points to carry out reuse activities. The EPR scheme must guarantee the quality and quantity available to reuse centres to achieve the target. Eco-mobilier’s 2014 annual report states that approximately 1.3 million tonnes of furniture are discarded each year in France. Of the household furniture recovered, the organisation reported recycling 48% in 2014, with 33% going to energy recovery, and the remainder being disposed of. No data is provided on the tonnage that was reused.63
The Kringwinkel shops in Flanders are often cited as being an example of reuse although they could be seen as falling in the category of preparation for reuse as well.64 The Kringwinkel website notes that the average person in Flanders bought 4.81 kg of reusable goods in 2014. They report having collected 65,930 tonnes of material in 2014, of which close to half (47%) could be prepared for reuse and sold on to customers.65
The organisation RREUSE has cited some figures on the amount of reuse occurring in different Member States:
“For example, social enterprise reuse networks are currently making available on the market 0.2 kg per capita of reused textiles, furniture and WEEE in Spain, 1.7 kg per capita in France and 2.3 kg per capita in Belgium.”66
If one were to multiply these rates by the population for each country this would amount to an estimated 9,288 tonnes for Spain, 25,894 tonnes for Belgium, and 112,799 tonnes for France being reused and/or prepared for reuse.67
The above illustrates that the current data on reuse is patchy and largely comprised of individual studies that have adopted different methodologies. There could also be some overlap in what is reported as reuse vs preparation for reuse. These factors make it particularly challenging to identify reliable sources of data on reuse.
6.3.3 Administrative Burden of Gathering Data on Reuse
An important consideration in developing a reuse target is the administrative burden associated with gathering the required data. The limited availability of data makes it equally challenging to provide an accurate assessment of the likely administrative costs of gathering this information. The available evidence that could be gathered as part of this study is presented below.
63 Eco-mobilier (undated) Rapport d’activité 2014: Les meubles sont des ressources d’avenir, www.eco-mobilier.fr, p. 2 64 Bio Intelligence Service, Copenhagen Resource Institure, and Regional Environmental Centre (2009) Best Practice Factsheets in Preparation for ‘Waste Prevention Guidelines’: Kringloop Reuse Centres (Flanders), June 2009, http://ec.europa.eu/environment/waste/prevention/pdf/Kringloop%20Reuse%20Centres_Factsheet.pdf 65 De Kringwinkel (2015) Sector in Cijfers, Date Accessed: October 2015, Available at: www.dekringwinkel.be/kw/over-ons/sector-in-cijfers_94.aspx 66 RREUSE (2015) Putting Reuse and Repair at the Heart of the EU’s Circular Economy Package, March 2015, www.rreuse.org/putting-reuse-and-repair-at-the-heart-of-circular-economy-legislation/, p. 4 67 Eurostat population estimates were used for the 1st January 2015; Eurostat (2015) Population on 1 January, Date Accessed: 27th October 2015, Available at: http://ec.europa.eu/eurostat/tgm/table.do?tab=table&init=1&language=en&pcode=tps00001&plugin=1
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6.3.3.1 Packaging Waste
Denmark and Finland are the two countries which routinely collect data on the reuse of packaging, and both countries were contacted to obtain some details on the amount of resource that was invested in order to gather the data presented above.
In Finland, the Finnish Packaging Recycling RINKI Ltd (RINKI) – that is, the producer compliance organisation covering packaging waste – compiles annual packaging statistics based on information supplied by its more than 4,000 members. Once compiled, the data is submitted to Pirkanmaa ELY Centre for Economic Development, Transport and the Environment (PirELY), who compiles the national data for Finland and sends it on to Eurostat.68
RINKI report that the data on the reuse of packaging waste is gathered and reported in the following way (Figure 6-6):
Reporting data on the amount of reusable packaging in circulation is integrated into the annual data collection and reporting obligations of producers who place packaging on the Finnish market.
The members of RINKI have always reported data on reuse along with other packaging statistics using a simple one-page form. RINKI reports that because reuse is often included in economic processes, it is monitored anyway, so the additional burden of reporting reuse is often only marginal.
If companies are using leased returnable transport packages – that is, returnable packing materials such as milk crates, beverage trays, roll containers, and pallets – they get reliable reuse figures from the leasing organisations based on the number of uses that have been invoiced.69
The total reuse figures for RINKI member companies is reported annually to the Finnish authorities as part of the broader reporting of packaging statistics. 70
68 Personal Communication with Finnish Packaging Recycling RINKI Ltd
69 In Finland there are several leasing systems for different kinds of returnable and reusable packaging, for
example: wooden pallets (e.g. FIN‐, EUR, CHEP‐pallets); “Dairy Pool” (plastic milk crates, trolleys etc.); “Ecobottle” (bottles, pallets, crates); “Mepak” (metal packaging; roll containers, crates, gas bottles, steel drums); and “Transbox” (plastic boxes). 70 Personal Communication with Finnish Packaging Recycling RINKI Ltd
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Figure 6-6: Data Flows for the Reporting of Data on Reusable Packaging
Source: Finnish Packaging Recycling RINKI Ltd
RINKI reports that: “Although 45% of Finnish producers report reuse of packaging yearly, most of them reuse only small amounts of packaging so data collection and reporting for them is easy”. Overall, 1.5 % of firms are responsible for 90% of total amount of reuse taking place each year. RINKI has further stated that:
“All facts considered, the additional burden associated with collecting data on the reuse [sic] is little and meaningless compared to the big picture when the data collection and reporting system is build [sic] and in action.”
In Denmark data on the reuse of packaging has been collected since 1995. Over the years, the statistics have reportedly only undergone minor changes; however, the approach to calculating the figures has remained unchanged.71 The quantity of reusable packaging in use each year is calculated based on the following factors:
Number of uses per year;
Number of rotations per year;
Number of units in rotation;
Weight per packaging;
Weight of reused packaging per year;
Total number of rotations in life time; and
Supply and outflow of reuse packaging per year.
Table 6-10 outlines how data on the above factors is gathered / calculated. The Danish Ministry of Environment and Food stated that the majority of the information and data was provided through voluntary co-operation with different associations and not by addressing each of the large companies that are involved in reuse. It was noted that in relation to reporting on the number of refillable beverage bottles and the associated crates was the data easiest to gather and report.
71 Personal communication with Danish Ministry of Environment and Food
Members of RINKI> 4,000 producers who place packaging on the
Finnish market
Suomen Palautuspakkaus and Other Deposit Refund
Members of PirELY8 companies
Finnish Packaging Recycling RINKI Ltd
Pirkanmaa ELY Centre for Economic Development, Transport
and the Environment
Eurostat
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The number of rotations per year and the lifetime of reuse packaging are key factors for estimating the amount of reuse packaging that flows through the market each year. The Danish Ministry of Environment and Food said that for much of the reused packaging there is no reliable data on the number of rotations / trips occurring each year as most of the packaging is not equipped with a bar code or an RFID tag for automatic data capture. Where the packaging contains such codes it is a lot easier to capture data on reuse cycles, but this does not yet appear to be common practice at present.
Table 6-10: Data Input Requirements for the Calculation of the Amount of Packaging Reuse in Denmark
Calculation Factor Input Type Description
Number of uses per year
Sales data, formula
The data are either sales data or calculated based on the number of units in rotation per year multiplied by the number of rotations per year. The sales data are provided for example by the Danish Brewers’ Association and the Danish Grocery Association
Number of rotations per year per reused packaging
Assessment This number is based on general experiences and dialogue with the relevant sectors
Number of units in rotation
Sales data, formula
These data are either sales data or calculated based on the total number of uses per year divided by the number of rotations per year
Weight per packaging, kg
Assessment This is the average weight per reuse packaging. There is a limited uncertainty on this figure
Weight of reused packaging per year, tonnes
Formula
This formula calculates the total weight of the used reuse packaging multiplied by the number of rotations per year. In case all used reuse packaging is to be substituted with single use packaging this figures shows the total weight that the general packaging consumption will be increased by, based on the assumption that a reuse packaging has the same weight as a single use version.
Total number of rotations in life time
Assessment This number is based on general experiences
Supply and outflow per year, number of reuse packaging
Formula This formula calculates the number of reuse packaging entering and leaving the stock of reuse packaging. This formula is only valid if the use of reuse packaging is constant throughout the years
Supply and outflow per year of reuse packaging, tonnes
Formula The formula converts the number of reuse packaging to the corresponding weight. The result is the total weight of the reused packaging entering and leaving the market each year.
Source: Danish Ministry of Environment and Food
A contact at the Danish Ministry of Environment and Food reported that the amount of time taken to gather data on the reuse of packaging was limited and cost no more than around €5,000 per annum. It was noted that if reuse was to be included in the EU recycling targets for packaging waste, the quality of the statistics could be increased markedly if the annual budget was increased to €40,0000.
6.3.3.2 Municipal Waste
Data on the reuse of products which pass through households – and thereby have the potential to land up in the municipal waste stream – has largely been estimated / gathered
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as part of independently commissioned studies. The detail and scope of these data vary widely depending on the available resources and the range of products / organisations being covered. No examples of routinely collected data on reuse at the Member State level could be found as part of this study.
Without a clear indication as to what products may or may not be included in a reuse target it is very difficult to estimate how much resources would be required to gather the required data. It would be necessary for the Commission to clearly stipulate how the data on reuse should be gathered. Indeed, this will be essential to ensure that a consistent approach is used across Member States. It would be necessary to define which types of reuse are to be included (e.g. textiles, furniture, or WEEE) and / or which reuse pathways that should be considered (e.g. second hand shops, car boot sales, online exchange platforms, charity donations, informal giving between friends and family and so on). The data on reuse could be gathered in two ways:
1) Directly from organisations and companies that facilitate reuse (whether through selling products on or charitable giving); or
2) Indirectly, for instance, by surveys of consumers/businesses, or monitoring of second hand retail outlets and online exchange platforms.
The way in which the data was gathered could be varied depending on the product group and the reuse pathway. For example, it may be possible to oblige retail outlets which sell second hand goods to report annually on the quantity of goods sold. For car boot sales, it may make more sense to quantify the amount of reuse via indirect means.
6.4 Assessing the Impact of a Combined Reuse Target
Given the numerous ways in which materials and products can be reused (e.g. reuse of cutlery and crockery in restaurants) it is essential to provide a very clear definition of what will be included in any reuse target. While this is certainly easier to do for packaging waste than for municipal waste, it is still not entirely clear as to where the boundary should be drawn. For instance, data from Denmark on the reuse of packaging waste includes 16,000 tonnes of metal butchers hooks which some could argue is not strictly packaging material (Table 6-4).
The sections below examine how a reuse target may be defined and discuss some of the key complexities that will have to be considered. Given some of the concerns raised about the level of ambition of the preparation for reuse / recycling targets the Commission was interested in understanding the extent to which the inclusion of reuse may make the targets easier to achieve. The main focus is, therefore, given to examining a combined target as opposed to considering how separate reuse targets may be set.
6.4.1 Packaging Waste
6.4.1.1 Target Definition
Research published by EUROPEN in response the Commission’s original legislative proposal provides a clear explanation of how reuse applies to the proposed packaging waste targets:
“The definition of ‘reuse’ in both existing and proposed legislation only applies to non-waste (i.e. multiple use packaging that is still in use) and concerns packaging in multiple-use systems. Only when such in-use packaging is discharged from the
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multiple-use system due to damage and/or reaching the maximum trips of rotation, does it become waste. Therefore, quantities that refer to ‘reuse’ packaging do not count towards the calculation of preparing for reuse and recycling targets.”72
The intention with the target discussed here would be to explicitly include the reuse of packaging in multiple-use systems. If a reuse target were to be developed for packaging waste, it could define the amount of packaging used per year as:
𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑝𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑤𝑎𝑠𝑡𝑒 𝑔𝑒𝑛𝑒𝑟𝑎𝑡𝑒𝑑 + 𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑝𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑟𝑒𝑢𝑠𝑒𝑑
Equation 2
Where the ‘amount of packaging reused’ is equal to:
𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑅𝑒𝑙𝑎𝑣𝑎𝑛𝑡 𝑅𝑒𝑢𝑠𝑎𝑏𝑙𝑒 𝑃𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑈𝑛𝑖𝑡𝑠 𝑖𝑛 𝑢𝑠𝑒 × 𝑤𝑒𝑖𝑔ℎ𝑡 𝑝𝑒𝑟 𝑈𝑛𝑖𝑡 × 𝑇𝑟𝑖𝑝𝑠 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟
Equation 3
The combined recycling target could be calculated as follows:
=𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑝𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑤𝑎𝑠𝑡𝑒 𝑝𝑟𝑒𝑝𝑎𝑟𝑒𝑑 𝑓𝑜𝑟 𝑟𝑒𝑢𝑠𝑒 & 𝑟𝑒𝑐𝑦𝑐𝑙𝑒𝑑 + 𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑝𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑟𝑒𝑢𝑠𝑒𝑑
𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑝𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑤𝑎𝑠𝑡𝑒 𝑔𝑒𝑛𝑒𝑟𝑎𝑡𝑒𝑑 + 𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑝𝑎𝑐𝑘𝑎𝑔𝑖𝑛𝑔 𝑟𝑒𝑢𝑠𝑒𝑑 100
Equation 4
6.4.1.2 Impact of Reuse on the Achievement of the Targets
The impact of applying a combined target (as set out in Equation 4) to data supplied by Denmark and Finland shows that both countries get very close to, or in many cases exceed, the Commission’s proposed targets for 2030 (Table 6-11). In line with the analysis undertaken for the supplement to the impact assessment (see Appendix A.1.0 for more details and the results of this analysis), this analysis considered a ‘higher’ and ‘lower’ rate and both are shown in Table 6-11 and referred to in the discussions below. The targets in the Commission's proposal correspond to the lower rates discussed below.
For each of the packaging waste streams identified in Table 6-11 an indication is given of the amount of reuse that is occurring as a proportion of the total amount of waste being generated. The data on wood packaging supplied by Denmark suggests that the weight of wood packaging being reused is almost three times greater (274%) than the total amount of wood packaging waste that was generated in 2013. The range of wood packaging considered in the Finnish data means that the amount of reuse is only 1.2 times greater (121%) than total arisings. The amount of metal packaging counted as being in some form or reuse cycle is also considerable, especially in Finland where it is assumed to be about 10 times (1009%) that of the actual amount of metal packaging waste that was generated in
72 Cyclos and HTP (2014) Impact Assessment: The European Commission’s Proposed Changes to the Calculation Method for National Packaging Recycling Rates (Executive Summary), Report for EUROPEN, October 2014, www.europen-packaging.eu/library/publications/11-guides/227-europens-impact-assessment-the-european-commissionas-proposed-changes-to-the-calculation-method-for-national-packaging-recycling-rates.html, p. 4
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2013. It is clear that the amount of reuse can potentially be very significant and could potentially be greater if either country decided to include other elements of packaging reuse.
Table 6-11: Impact of Including Packaging Reuse in Denmark and Finland’s Packaging Waste Recycling Targets (2013)
Packaging Material
a b C a/b*100 c/b*100 (a+c)/(a+b)*100
Recycling Targets for
20303 Packaging Reused1
Packaging Waste
Generated2
Packaging Waste
Recycled2
Reuse as a Proportion
of Total Waste
Generated
Recycling Rate
Combined Reuse and Recycling
Rate Low High
thousand tonnes %
DENMARK
Plastic 151 1904 68 80% 36% 64% 55% 60%
Metal 105 534 30 198% 57% 86% 85% 90%
Glass 113 146 114 77% 78% 87% 85% 90%
Paper / Card
0 375 320 0% 85% 85% 85% 90%
Wood 501 183 85 274% 47% 86% 75% 80%
Total 870 947 618 92% 65% 82% 75% 60%
FINLAND
Plastic 244 118 27 207% 23% 75% 55% 60%
Metal 519 51 42 1009% 82% 98% 85% 90%
Glass 29 82 63 35% 77% 83% 85% 90%
Paper / Card
20 259 252 8% 98% 98% 85% 90%
Wood 251 207 31 121% 15% 62% 75% 80%
Total 1,062 717 415 148% 58% 83% 75% 60%
Notes:
1. Data provided as part of Member State consultation – see Section 6.2.
2. Data obtained from Eurostat (2015) Recycling Rates for Packaging Waste (ten00063), Date Accessed: 20th October 2015, Available at: http://ec.europa.eu/eurostat/web/environment/waste/main-tables.
3. See Section 3.0 of Appendix A.1.0 for more details on the proposed packaging waste targets.
4. The data provided by Denmark (Table 6-4) included a category for metal and plastic ‘drums/containers’. It was assumed that the recorded weight was split evenly between metals and plastics.
Data was also obtained on the amount of refillable beverage packaging being reused in five Member States. This is a much narrower scope of materials than considered by Denmark and Finland; however, it still provides a useful point of comparison. Table 6-12 shows how, for Austria, France, Germany, Italy, and Sweden, the inclusion of reused beverage packaging may contribute to a combined target for each country. Other than for the reuse of glass bottles in Austria and Germany the ratio of reuse to the amount of waste generated is, as one would expect, lower than that reported by Denmark and Finland both of which include a broader range of packaging materials.
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Table 6-12: Impact of Including Refillable Beverage Packaging Units in Five Member States’ Packaging Waste Recycling Targets (2012)
Packaging Material
a b c a/b*100 c/b*100 (a+c)/(a+b)*100 Recycling Targets for
20303 Packaging Reused1
Packaging Waste
Generated2
Packaging Waste
Recycled2
Reuse as a Proportion
of Total Waste
Generated
Recycling Rate
Combined Reuse and Recycling
Rate Low High
thousand tonnes %
AUSTRIA
Glass 432 271 225 159% 83% 93% 85% 90%
Plastic 1 272 94 0% 35% 35% 55% 60%
Metal 48 64 39 75% 61% 78% 85% 90%
Total 480 607 358 79% 59% 77% 75% 80%
FRANCE
Glass 161 2,712 1,992 6% 73% 75% 85% 90%
Plastic 0 1,998 502 0% 25% 25% 55% 60%
Metal 183 588 434 31% 74% 80% 85% 90%
Total 344 5,297 2,928 7% 55% 58% 75% 80%
GERMANY
Glass 5,180 2,807 2,377 185% 85% 95% 85% 90%
Plastic 363 2,837 1,405 13% 50% 55% 55% 60%
Metal 399 905 835 44% 92% 95% 85% 90%
Total 5,942 6,548 4,616 91% 70% 85% 75% 80%
ITALY
Glass 466 2,212 1,568 21% 71% 76% 85% 90%
Plastic 0 2,052 770 0% 38% 38% 55% 60%
Metal 84 506 373 17% 74% 77% 85% 90%
Total 549 4,770 2,711 12% 57% 61% 75% 80%
SWEDEN
Glass 77 199 176 39% 88% 91% 85% 90%
Plastic 2 214 75 1% 35% 36% 55% 60%
Metal 10 59 44 16% 74% 78% 85% 90%
Total 89 471 294 19% 62% 68% 75% 80%
Notes:
1. Based on Canadean data – see Section 6.3.
2. Data obtained from Eurostat (2015) Recycling Rates for Packaging Waste (ten00063), Date Accessed: 20th October 2015, Available at: http://ec.europa.eu/eurostat/web/environment/waste/main-tables.
3. See Section 3.0 of Appendix A.1.0 for more details on the proposed packaging waste targets.
As noted in Section 6.1 (Table 6-1 / Figure 6-2), the amount of reuse that occurs relative to the total weight of waste being generated can have a substantial impact on the final outcome of the combined target put forward in Table 6-11. With the above proportions in mind it is useful to consider how much reuse of packaging materials would be required to
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enable Member States to achieve the recycling targets proposed by the Commission for 2030. Considering the lower of the Danish and Finnish figures for the share of reuse in total waste generated, it is possible to indicate which Member States would achieve the relevant target if they had similar shares of reuse.
Table 6-13 shows the quantity of plastic packaging waste that was generated across all Member States in 2012 (the latest year for which data was available for all countries at the time of writing). The amount of plastic packaging that was recycled is also shown, along with the resulting recycling rate. For each Member State, Table 6-13 shows the amount of plastic packaging that would need to be being reused for the country to be already meeting the proposed 2030 targets (i.e. without further recycling or preparation for reuse).
It can be seen from this that the ratio of the amount of reuse required to meet the target as a proportion of the plastic packaging waste generated ranges quite widely. If Member States’ recycling rates were to remain static and they were to rely on reuse to achieve a combined target of 55% they would have to prove that they were reusing an amount of plastic packaging equivalent to between 8% (Romania) and 73% (Poland) of the total amount of plastic packaging waste generated in 2012 (the figures increase if the target is raised to 90%). The amount of reused plastic packaging reported by Denmark amounts to 80% of the total amount of waste generated, whereas for Finland it is more than double this at 207%.
Table 6-13: Amount of Reuse of Plastic Packaging Required to Move from Current Levels of Recycling to Achieving a Combined Target of 55% / 60% (2012)
Member State
Waste Generated1
Waste Recycled1
Recycling Rate1
2030 Targets2
Low: 55% High: 60% Low: 55% High: 60%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Austria 272 94 34.65% 123 172 45% 63%
Belgium 320 133 41.53% 96 148 30% 46%
Bulgaria 96 39 40.75% 30 46 32% 48%
Croatia 48 22 45.38% 10 18 21% 37%
Cyprus 15 7 44.85% 3 6 23% 38%
Czech Republic 212 123 58.21% 0 9 - 4%
Denmark 184 54 29.37% 105 141 57% 77%
Estonia 48 14 29.77% 27 36 56% 76%
Finland 117 30 25.39% 77 101 66% 87%
France 1,998 502 25.11% 1,327 1,743 66% 87%
Germany 2,837 1,405 49.53% 345 743 12% 26%
Greece 185 60 32.22% 94 128 51% 69%
Hungary 257 71 27.76% 156 207 61% 81%
Ireland 169 68 40.42% 55 83 32% 49%
Italy 2,052 770 37.52% 797 1,153 39% 56%
Latvia 37 9 23.99% 25 33 69% 90%
Lithuania 60 23 38.88% 21 32 36% 53%
Luxembourg 24 9 36.74% 10 14 41% 58%
88
Member State
Waste Generated1
Waste Recycled1
Recycling Rate1
2030 Targets2
Low: 55% High: 60% Low: 55% High: 60%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Malta 11 4 32.78% 5 7 49% 68%
Netherlands 459 219 47.71% 74 141 16% 31%
Poland 832 185 22.18% 607 787 73% 95%
Portugal 350 107 30.42% 191 259 55% 74%
Romania 298 153 51.29% 25 65 8% 22%
Slovakia 105 60 56.99% 0 8 - 8%
Slovenia 45 29 64.81% 0 0 - -
Spain 1,304 458 35.15% 576 811 44% 62%
Sweden 214 75 34.91% 95 134 45% 63%
United Kingdom 2,554 644 25.23% 1,690 2,220 66% 87%
EU28 15,101 5,365 35.53% 6,535 9,239 43% 61%
Notes:
1. All data refers to 2012 figures. Obtained from Eurostat (2015) Recycling Rates for Packaging Waste (ten00063), Date Accessed: 20th October 2015, Available at: http://ec.europa.eu/eurostat/web/environment/waste/main-tables.
2. See Section 3.0 of Appendix A.1.0 for more details on the proposed packaging waste targets.
Figure 6-7 shows that if the amount of reuse occurring in any of the Member States was the same as that reported by Denmark, then only five Member States would not be able to achieve the 60% target (though Finland would meet the target applying its own reported rate of reuse), with all able to meet the 55% target (without making any further progress on recycling). It is obvious from the same Figure that if all countries reported reuse rates similar to that of Finland, all countries would meet a combined 60% target. Such an outcome – where no further action is required – is not well aligned with the aspirations set out in documents such as the Resource Efficiency Roadmap (including 2020 aspirational targets)73 and the 7th Environmental Action Programme.74 This suggests one of three possible options:
1) Either increasing the level of the combined target to allow for combined reporting which will still act to increase recycling and reuse;
2) Maintain a preparation for reuse target alongside the combined target, with the latter being amended and revised in line with experience; and
3) Reduce the scope of packaging that can be counted towards the combined target.
73 European Commission (2011) Roadmap to a Resource Efficient Europe, COM(2011) 571 final, http://ec.europa.eu/environment/resource_efficiency/about/roadmap/index_en.htm 74 Decision of the European Parliament and of the Council (2013) Decision of the European Parliament and of the Council on a General Union Environment Action Programme to 2020 "Living Well, Within the Limits of our Planet", November 2013, http://ec.europa.eu/environment/newprg/
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Figure 6-7: Comparison of Reuse Data for Plastic Packaging in Table 6-13 to Finnish and Danish Data
With a view to the reuse of metal packaging, it can be seen from Table 6-14 that a rather larger volume of reuse, relative to the total amount of metal packaging waste generated, will be required for Member States to meet a combined target if they make no further efforts on improving recycling. For a 85% target Member States would have to reuse between 17% (Luxembourg) and 483% (Croatia) of the total amount of metal packaging waste generated. This range increases to between 47% and 775% for a 90% target. A comparison of these rates against the amount of metal packaging which is being reused in Denmark and Finland is provided in Figure 6-8.
Table 6-14: Amount of Reuse of Metal Packaging Required to Move from Current Levels of Recycling to Achieving a Combined Target of 85% / 90% (2012)
Member State
Waste Generated1
Waste Recycled1
Recycling Rate1
2030 Recycling Targets2
Low: 85% High: 90% Low: 85% High: 90%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Austria 64 39 61.38% 101 183 157% 286%
Belgium 127 124 97.33% 0 0 - -
Bulgaria 15 11 75.57% 9 21 63% 144%
Croatia 9 1 12.55% 41 66 483% 775%
Cyprus 7 7 98.75% 0 0 - -
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55% Target 60% Target Denmark Finland
90
Member State
Waste Generated1
Waste Recycled1
Recycling Rate1
2030 Recycling Targets2
Low: 85% High: 90% Low: 85% High: 90%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Czech Republic 54 38 69.21% 57 113 105% 208%
Denmark 45 24 51.84% 100 173 221% 382%
Estonia 28 18 65.29% 37 69 131% 247%
Finland 50 43 85.27% 0 24 - 47%
France 588 434 73.90% 435 946 74% 161%
Germany 905 835 92.30% 0 0 - -
Greece 106 40 38.21% 330 548 312% 518%
Hungary 67 54 80.82% 19 61 28% 92%
Ireland 48 37 75.76% 30 69 62% 142%
Italy 506 373 73.65% 383 828 76% 164%
Latvia 10 6 57.77% 19 34 182% 322%
Lithuania 15 10 67.16% 17 33 119% 228%
Luxembourg 4 4 82.39% 1 3 17% 76%
Malta 4 2 41.54% 11 19 290% 485%
Netherlands 193 175 90.67% 0 0 - -
Poland 249 116 46.87% 632 1,072 254% 431%
Portugal 89 64 72.32% 75 157 85% 177%
Romania 58 32 55.54% 115 201 196% 345%
Slovakia 24 16 67.77% 27 52 115% 222%
Slovenia 15 6 41.62% 44 74 289% 484%
Spain 415 324 78.01% 193 497 47% 120%
Sweden 59 44 74.37% 42 92 71% 156%
United Kingdom 808 420 52.06% 1,774 3,064 220% 379%
EU28 4,559 3,296 72.28% 3,866 8,078 85% 177%
Notes:
1. All data refers to 2012 figures. Obtained from Eurostat (2015) Recycling Rates for Packaging Waste (ten00063), Date Accessed: 20th October 2015, Available at: http://ec.europa.eu/eurostat/web/environment/waste/main-tables.
2. See Section 3.0 of Appendix A.1.0 for more details on the proposed packaging waste targets.
Figure 6-8 shows that if Member States were to have the same levels of reuse as those which prevail in Denmark, then only six countries would not be meeting the lower target for 2030 whilst a further six would not be meeting the higher target. All countries would meet the target if reuse were at levels reported by Finland. Similar comments apply as with plastic (i.e. it might be necessary to increase the targets further, maintain recycling and preparation for reuse targets alongside the combined target, or restrict the scope of packaging to be considered under the reuse target). The amount of metal beverage packaging reused is a lot lower than that reported by Denmark and Finland, with Austria reporting the highest rate, which is equivalent to an estimated 75% of the metal packaging waste generated in 2012.
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Figure 6-8: Comparison of Reuse Data for Metal Packaging in Table 6-14 to Finnish and Danish Data
A number of Member States – that is, Belgium, Ireland, Luxembourg, Slovenia, and Sweden – are already reporting that they recycle more than 85% of their glass packaging waste (Table 6-15). The remaining Member States could hypothetically achieve a combined target of 85% by proving that the reuse of glass packaging within their countries was between 2% (Germany) and 425% (Malta) of the amount of glass packing waste generated in 2012 (the range increases to 18%–687% for meeting the 90% target). These required reuse rates are compared with the reuse rate of Finland (35%) and Denmark (77%) in Figure 6-9. If other countries were to record the same levels of reuse as in Finland, it would help them some way towards the suggested targets, but they would still have to increase the rate of glass recycling to ensure that a combined target of 85%/90% could be achieved. At a reuse rate of 35%, nine Member States would be meeting the lower target, but for five of these this is through existing recycling rates.
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85% Target 90% Target Denmark Finland
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Table 6-15: Amount of Reuse of Glass Packaging Required to Move from Current Levels of Recycling to Achieving a Combined Target of 85% / 90% (2012)
Member State
Waste Generated1
Waste Recycled1
Recycling Rate1
2030 Recycling Targets2
Low: 85% High: 90% Low: 85% High: 90%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Austria 271 225 82.88% 38 193 14% 71%
Belgium 396 396 100.00% 0 0 - -
Bulgaria 71 43 60.51% 115 208 163% 295%
Croatia 53 33 62.78% 78 143 148% 272%
Cyprus 17 6 32.40% 61 101 351% 576%
Czech Republic 194 157 81.12% 50 172 26% 89%
Denmark 150 121 80.63% 44 141 29% 94%
Estonia 38 27 70.74% 36 73 95% 193%
Finland 83 65 77.57% 41 103 50% 124%
France 2,712 1,992 73.46% 2,086 4,485 77% 165%
Germany 2,807 2,377 84.67% 63 1,497 2% 53%
Greece 100 54 54.66% 201 352 202% 353%
Hungary 107 36 34.16% 361 595 339% 558%
Ireland 148 126 85.47% 0 67 - 45%
Italy 2,212 1,568 70.90% 2,079 4,225 94% 191%
Latvia 52 29 55.11% 103 181 199% 349%
Lithuania 64 46 72.23% 55 114 85% 178%
Luxembourg 29 28 94.63% 0 0 - -
Malta 11 2 21.31% 45 73 425% 687%
Netherlands 536 382 71.27% 491 1,004 92% 187%
Poland 1,057 541 51.24% 2,378 4,096 225% 388%
Portugal 362 216 59.55% 615 1,103 170% 304%
Romania 160 106 66.26% 200 380 125% 237%
Slovakia 75 52 69.38% 78 155 104% 206%
Slovenia 32 28 87.29% 0 9 - 27%
Spain 1,398 897 64.20% 1,939 3,607 139% 258%
Sweden 199 176 88.19% 0 36 - 18%
United Kingdom 2,399 1,627 67.80% 2,752 5,327 115% 222%
EU28 15,732 11,356 72.18% 13,443 28,030 85% 178%
Notes:
1. All data refers to 2012 figures. Obtained from Eurostat (2015) Recycling Rates for Packaging Waste (ten00063), Date Accessed: 20th October 2015, Available at: http://ec.europa.eu/eurostat/web/environment/waste/main-tables.
2. See Section 3.0 of Appendix A.1.0 for more details on the proposed packaging waste targets.
Denmark would meet the lower target at its own level of reuse. At the higher rate of reuse reported by Denmark, only France and Finland are added to the number of countries
93
meeting the lower rate target. This reflects the fact that, relative to the packaging being generated, the reuse of glass accounts for a smaller fraction of the total waste generated. However, this will clearly vary from country to country and appears to be much higher in countries such as Germany (185%) and Austria (159%) which still use a large number of refillable glass bottles (Table 6-12).
Figure 6-9: Comparison of Reuse Data for Glass Packaging in Table 6-15 to Finnish and Danish Data
Table 6-16 shows the quantity of paper and cardboard packaging waste generated and recycled across all Member States in 2012. It can be seen that many Member States already meet the lower and higher targets for paper and card of 85% and 90%. Given the lack of durability of paper and cardboard, it is unlikely that reuse will play a significant role for these materials. Indeed, Denmark assumes that no reuse of paper and card occurs, whilst Finland reports that the reuse of products made from these materials only amounted to 8% of the total amount of waste generated in 2013. The low probability of there being large amounts of reuse in relation to paper and card means that if a combined target were allowed for this packaging stream Member States would still be required to improve their recycling performance (Figure 6-10).
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Table 6-16: Amount of Reuse of Paper/Cardboard Packaging Required to Move from Current Levels of Recycling to Achieving a Combined Target of 85% / 90% (2012)
Member State
Waste Generated1
Waste Recycled1
Recycling Rate1
2030 Recycling Targets2
Low: 85% High: 90% Low: 85% High: 90%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Austria 516 438 84.90% 4 264 1% 51%
Belgium 659 592 89.85% 0 10 - 2%
Bulgaria 122 115 94.24% 0 0 - -
Croatia 65 62 96.06% 0 0 - -
Cyprus 25 22 88.92% 0 3 - 11%
Czech Republic 380 326 85.91% 0 155 - 41%
Denmark 368 281 76.55% 207 495 56% 135%
Estonia 66 51 77.21% 34 85 52% 128%
Finland 253 252 99.24% 0 0 - -
France 4,807 4,411 91.77% 0 0 - -
Germany 7,272 6,373 87.64% 0 1,717 - 24%
Greece 337 282 83.59% 32 216 9% 64%
Hungary 409 299 73.02% 327 695 80% 170%
Ireland 359 298 83.04% 47 250 13% 70%
Italy 4,255 3,594 84.45% 155 2,360 4% 55%
Latvia 61 46 75.34% 40 90 64% 147%
Lithuania 86 71 82.44% 15 65 17% 76%
Luxembourg 30 23 76.72% 17 40 55% 133%
Malta 22 17 77.22% 11 28 52% 128%
Netherlands 1,129 1,004 88.93% 0 121 - 11%
Poland 1,493 793 53.13% 3,173 5,505 212% 369%
Portugal 647 427 66.05% 817 1,549 126% 239%
Romania 303 212 69.84% 306 611 101% 202%
Slovakia 184 156 84.71% 4 97 2% 53%
Slovenia 79 62 78.66% 34 90 42% 113%
Spain 3,241 2,523 77.84% 1,546 3,939 48% 122%
Sweden 509 391 76.85% 277 670 54% 132%
United Kingdom 3,848 3,328 86.47% 0 1,357 - 35%
EU28 31,527 26,451 83.90% 2,316 19,237 7% 61%
Notes:
1. All data refers to 2012 figures. Obtained from Eurostat (2015) Recycling Rates for Packaging Waste (ten00063), Date Accessed: 20th October 2015, Available at: http://ec.europa.eu/eurostat/web/environment/waste/main-tables.
2. See Section 3.0 of Appendix A.1.0 for more details on the proposed packaging waste targets.
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Figure 6-10: Comparison of Reuse Data for Paper and Cardboard Packaging in Table 6-16 to Finnish Data
If reuse were allowed to count towards the recycling targets for wood packaging of 75% (low rate) and 80% (higher rate), Member States could achieve the 75% target by freezing their current recycling rates and reporting that the quantity of wood packaging reused was between 21% and 298% of the total amount of wood packaging waste generated (Table 6-17).
Table 6-17: Amount of Reuse of Wood Packaging Required to Move from Current Levels of Recycling to Achieving a Combined Target of 75% / 80% (2012)
Member State
Waste Generated1
Waste Recycled1
Recycling Rate1
2030 Recycling Targets2
Low: 75% High: 80% Low: 75% High: 80%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Austria 88 19 21.48% 189 258 214% 293%
Belgium 199 131 66.09% 71 138 36% 70%
Bulgaria 20 11 53.06% 18 27 88% 135%
Croatia 24 0 0.43% 72 96 298% 398%
Cyprus 7 0 6.16% 20 27 275% 369%
Czech Republic 95 24 25.70% 188 259 197% 272%
Denmark 143 58 40.42% 197 282 138% 198%
Estonia 18 11 59.73% 11 18 61% 101%
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Member State
Waste Generated1
Waste Recycled1
Recycling Rate1
2030 Recycling Targets2
Low: 75% High: 80% Low: 75% High: 80%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Finland 211 36 16.89% 490 665 232% 316%
France 2,148 615 28.63% 3,984 5,518 185% 257%
Germany 2,743 830 30.26% 4,909 6,822 179% 249%
Greece 41 17 41.81% 54 78 133% 191%
Hungary 173 31 18.14% 393 534 227% 309%
Ireland 85 70 82.31% 0 0 - -
Italy 2,320 1,257 54.18% 1,932 2,995 83% 129%
Latvia 53 20 36.74% 81 115 153% 216%
Lithuania 75 37 48.82% 79 117 105% 156%
Luxembourg 16 4 23.36% 34 46 207% 283%
Malta 4 0 0.76% 12 16 297% 396%
Netherlands 423 124 29.31% 773 1,072 183% 253%
Poland 1,040 296 28.51% 1,933 2,676 186% 257%
Portugal 80 56 69.70% 17 41 21% 52%
Romania 240 99 41.15% 325 466 135% 194%
Slovakia 53 19 36.74% 81 115 153% 216%
Slovenia 29 9 33.06% 48 67 168% 235%
Spain 353 204 57.91% 241 390 68% 110%
Sweden 301 52 17.16% 697 947 231% 314%
United Kingdom 1,024 525 51.28% 972 1,470 95% 144%
EU28 12,006 4,555 37.94% 17,796 25,247 148% 210%
Notes:
1. All data refers to 2012 figures. Obtained from Eurostat (2015) Recycling Rates for Packaging Waste (ten00063), Date Accessed: 20th October 2015, Available at: http://ec.europa.eu/eurostat/web/environment/waste/main-tables.
2. See Section 3.0 of Appendix A.1.0 for more details on the proposed packaging waste targets.
The amount of wood packaging reused in Finland and Denmark was 121% and 274%, respectively. At the lower of these two levels, whilst ten Member States would be achieving the lower rate for 2030, six would be meeting the higher rate specified. At the higher of the two reuse rates, 26 Member States would meet the lower target, and 20 would meet the higher target (though Finland would not meet either target at its own reuse rate). There is clearly some uncertainty around how reuse will affect attainment of the proposed targets where wood is concerned
The only wooden packaging items reported by Denmark (Finland did not provide a breakdown of the data by product) were pallets and cable drums. In total, wooden pallets accounted for an estimated 500,000 tonnes of reuse in 2013, compared to a mere 1,000 tonnes from cable drums. Considered apart, the weight of wooden pallets was 273% of the amount of wooden packaging waste generated in the same year. This means that reuse,
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even if only wooden pallets are taken into account, exerts a very strong impact on the combined rate of reuse and recycling.
The reuse of wooden packaging may prove to be an area of great uncertainty, as it is hard to quantify at this stage the amount of wooden pallets that may be in use in different Member States. Given their weight and their prevalence in many countries, the tonnages could be substantial.
Figure 6-11: Comparison of Reuse Data for Wood Packaging in Table 6-17 to Finnish and Danish Data
6.4.1.3 Summary
The above provides a basic outline of the challenges associated with including reuse in the proposed packaging waste targets. Given the paucity of data on reuse, a lot of reliance had to be placed on only two sources of data – namely, Finland and Denmark. Although one would ideally draw comparisons from a much larger sample, the available data suggests that including reuse in a combined target would have to account for the relative ease with which this allows the proposed targets to be met. This varies across materials. Broadly speaking, including reuse in a combined target would appear to make it:
Much easier to achieve the proposed targets for plastic, metals and, probably, wood; and
Somewhat easier for glass;
With the least impact on paper and card.
For these reasons, combined targets should probably be higher for plastics, metals and wood. The rationale for doing so for glass is weaker as the share of reusable glass
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packaging varies across countries, whilst the paper and card target would be largely unaffected by the reuse target (although the combined target could potentially trigger some attempts to gainsay the targets by making assumptions regarding how many paper bags, for example, are used in the household for another purpose).
One interesting approach would be to have both a recycling and preparation for reuse target, alongside a combined target which includes reuse.
Finally, a final possibility would be to restrict the extent to which reuse is considered as contributing to the target. Even so, the nature and extent of that restriction may still have implications for the way in which the combined targets are set, as the example of wood (see above) clearly shows.
6.4.2 Municipal Waste
6.4.2.1 Target Definition
A combined target which included reuse would likely have to look very similar to that suggested for packaging waste and could be calculated as follows for any given year:
=𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑀𝑆𝑊 𝑝𝑟𝑒𝑝𝑎𝑟𝑒𝑑 𝑓𝑜𝑟 𝑟𝑒𝑢𝑠𝑒 & 𝑟𝑒𝑐𝑦𝑐𝑙𝑒𝑑 + 𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑚𝑢𝑛𝑖𝑐𝑖𝑝𝑎𝑙 𝑝𝑟𝑜𝑑𝑢𝑐𝑡𝑠 𝑟𝑒𝑢𝑠𝑒𝑑
𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑀𝑆𝑊 𝑔𝑒𝑛𝑒𝑟𝑎𝑡𝑒𝑑 + 𝑎𝑚𝑜𝑢𝑛𝑡 𝑜𝑓 𝑚𝑢𝑛𝑖𝑐𝑖𝑝𝑎𝑙 𝑝𝑟𝑜𝑑𝑢𝑐𝑡𝑠 𝑟𝑒𝑢𝑠𝑒𝑑 100
Equation 5
Where the ‘amount of municipal products reused’ in a year is equal to:
𝑛𝑢𝑚𝑏𝑒𝑟 𝑜𝑓 𝑅𝑒𝑙𝑎𝑣𝑎𝑛𝑡 𝑅𝑒𝑢𝑠𝑎𝑏𝑙𝑒 𝑈𝑛𝑖𝑡𝑠 𝑟𝑒𝑢𝑠𝑒𝑑 × 𝑤𝑒𝑖𝑔ℎ𝑡 𝑝𝑒𝑟 𝑈𝑛𝑖𝑡 × 𝑇𝑟𝑖𝑝𝑠 𝑝𝑒𝑟 𝑦𝑒𝑎𝑟
Equation 6
The definition of Relevant Reusable Unit would need to be restricted to those items which can reasonably be assumed to eventually arise as waste in the municipal waste stream.
From the Member State consultation it would appear that Relevant Reusable Units could include such items as electrical and electronic equipment, textiles, furniture, toys, and packaging waste (Table 6-2). The key challenge, however, is the lack of data on the quantities of these materials that are being reused in European Member States: even if data regarding this was readily available, there might also be a challenge in linking reuse back to a Member State’s definition of municipal waste (hence the relevance of a harmonised definition). The reuse of products should only count towards the target if it is preventing waste from arising in the municipal waste stream. Making this judgement (what, of the reused items, could have been ‘municipal waste’) is far from easy, especially when there is no consistent definition of what should be included and excluded from the definition (see Section 3.0 for a detailed discussion on different approaches to defining municipal waste). It would be difficult to assess whether products which have been reused, say, for example, via online portals or second hand shops, would have otherwise been discarded as part of the municipal waste stream.
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6.4.2.2 Impact of Reuse on the Achievement of the Targets
The data on the reuse of household products is very limited (Section 6.3.2). The studies that were identified showed little consistency in terms of the method whereby the data were gathered and the range of materials covered. It is, therefore, challenging to build up a clear picture of the extent to which reuse may contribute to the achievement of the proposed targets put forward by the Commission. Nevertheless, it is still instructive to examine what proportion the reported levels of reuse are in relation to the total amount of MSW that is being generated. Based on the small amount of available data for only a few products it would seem that the amount of reuse, as a proportion of the total amount of MSW generated, is far more limited for municipal waste than for packaging waste.
Table 6-18 shows that the reuse data obtained as part of this review weighs less than 0.04% (Spain) and 3.87% (France) of total MSW arisings. If these results are representative, then it would seem that combining these rates of reuse with the existing preparation for reuse/recycling tonnages would result in only a marginal uplift in each country’s overall performance. If more materials were reported as having been reused – something which could easily be achieved if the scope of materials covered were to be extended – then the impact would obviously be greater, but how much greater is far from clear.
Table 6-18: Impact of Including Reuse in Member States’ MSW Preparation for Reuse and Recycling Targets (2013)
Member State
a b c a/b*100 c/b*100 (a+c)/(a+b)*100
Amount of
Reuse1
MSW Generated2
MSW Prepared for
Reuse /Recycled2
Reuse as a Proportion of Total Waste Generated
Recycling Rate
Combined Reuse and Recycling
Rate
thousand tonnes %
Belgium 26 4,905 2,700 0.53% 55.05% 55.28%
France 1,347 34,828 13,097 3.87% 37.60% 39.93%
Spain 9.3 20,931 6,287 0.04% 30.04% 30.07%
United Kingdom 588 30,890 13,427 1.9% 43.47% 44.52%
Notes:
1. The amount of reuse in each country is taken from Section 6.3. Belgium and Spain: RREUSE (2015) Putting Reuse and Repair at the Heart of the EU’s Circular Economy Package, March 2015, www.rreuse.org/putting-reuse-and-repair-at-the-heart-of-circular-economy-legislation/; France: ADEME (2014) Panorama de la Deuxieme vie des Produits en France, October 2014, www.ademe.fr/sites/default/files/assets/documents/panorama-de-la-2eme-vie-des-produits-reemploi-synthese-2014_3.pdf; United Kingdom: data based on sum of reuse figures presented in Table 6-7, Table 6-8, and Table 6-9.
2. Data obtained from Eurostat (2015) Recycling Rates for Packaging Waste (ten00063), Date Accessed: 20th October 2015, Available at: http://ec.europa.eu/eurostat/web/environment/waste/main-tables.
Table 6-19 shows the amount of reuse that would be required to take Member States from their 2013 levels of recycling to achieving a combined target of 65% or 70% (these are the MSW preparation for reuse / recycling targets which were analysed as part of the supplement to the impact assessment – Section 3.0 of Appendix A.1.0). It can be seen that in order for Member States to achieve a combined target of 65%, while at their current rates of recycling, the weight of Relevant Reusable Units being reused has to be equivalent
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to between 1% (Germany) and 178% (Romania) of the total amount of MSW being generated. Clearly, the fact that the recycling rates in the two countries are so different plays an important role in determining the relative proportion of reuse that will be required. Likewise, Member States could automatically achieve a combined target of 70% if they could be shown to be reusing an amount of material equivalent to between 18% and 225% of MSW arisings.
Table 6-19: Amount of Reuse Required to Move from Current Levels of Recycling to Achieving a Combined Target of 65% / 70% (2013)
Member State
Waste Generated1
Waste Prepared for Ruse / Recycled1
Prepara-tion for Reuse /
Recycling Rate 1
2030 Recycling Targets2
Low: 65% High: 70% Low: 65% High: 70%
Amount of Reuse Required to Meet
Target
Amount of Reuse as a Proportion of Total Waste Generated
thousand tonnes % thousand tonnes %
Austria 4,905 2,753 56% 1,244 2,268 25% 46%
Belgium 4,905 2,700 55% 1,395 2,445 28% 50%
Bulgaria 3,135 894 29% 3,268 4,335 104% 138%
Croatia 1,721 257 15% 2,462 3,159 143% 184%
Cyprus 538 115 21% 671 872 125% 162%
Czech Republic 3,228 782 24% 3,761 4,925 116% 153%
Denmark 4,192 1,857 44% 2,479 3,591 59% 86%
Estonia 386 67 17% 525 677 136% 175%
Finland 2,682 872 33% 2,489 3,351 93% 125%
France 34,828 13,097 38% 27,261 37,609 78% 108%
Germany 49,780 32,112 65% 700 9,113 1% 18%
Greece 5,585 1,078 19% 7,292 9,438 131% 169%
Hungary 3,738 987 26% 4,122 5,432 110% 145%
Ireland 2,693 985 37% 2,187 3,000 81% 111%
Italy 29,595 11,654 39% 21,665 30,208 73% 102%
Latvia 627 106 17% 862 1,110 137% 177%
Lithuania 1,280 356 28% 1,360 1,800 106% 141%
Luxembourg 355 170 48% 174 262 49% 74%
Malta 241 25 10% 376 479 156% 199%
Netherlands 8,845 4,408 50% 3,832 5,945 43% 67%
Poland 11,295 2,730 24% 13,176 17,255 117% 153%
Portugal 4,598 1,187 26% 5,148 6,772 112% 147%
Romania 5,441 139 3% 9,708 12,232 178% 225%
Slovakia 1,645 177 11% 2,549 3,248 155% 197%
Slovenia 853 364 43% 544 777 64% 91%
Spain 20,931 6,287 30% 20,909 27,882 100% 133%
Sweden 4,399 2,178 50% 1,947 3,004 44% 68%
United Kingdom 30,890 13,427 43% 19,004 27,320 62% 88%
EU28 243,311 101,764 42% 161,109 228,512 66% 94%
Notes:
1. Data obtained from Eurostat for the year 2013 – Eurostat (2015) Municipal Waste [env_wasmun], Date Accessed: 23 June 2015, Downloaded from: http://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_wasmun&lang=en.
2. See Section 3.0 of Appendix A.1.0 for more details on the proposed MSW preparation for reuse and recycling targets.
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6.4.2.3 Summary
The key challenge in relation to including reuse within the MSW preparation for reuse and recycling targets is that there is very little data available that can be used to provide a clear indication of the likely impact that this may have on current performance levels under the targets. Indeed, this was one of the main concerns raised by Member States in the consultation.
A possible option would be to keep the existing preparation for reuse and recycling targets separate, but to allow Member States to start reporting on reuse until improved data can be obtained and a more detailed assessment undertaken.
If reuse is going to be allowed to count towards the MSW preparation for reuse/recycling targets it would be necessary for the Commission to clearly stipulate how the data on reuse should be gathered. Indeed, this will be essential to ensure that a consistent approach is used across Member States. It would be necessary to define which types of reuse are to be included (e.g. textiles, furniture, or WEEE) and / or which reuse pathways should be considered (e.g. second hand shops, car boot sales, online exchange platforms, charity donations, informal giving between friends and family and so on). The data on reuse could be gathered in two ways:
1) Directly from organisations and companies that facilitate reuse (whether through selling products on or charitable giving); or
2) Indirectly, for instance, by surveys of consumers/businesses, or monitoring of second hand retail outlets and online exchange platforms.
The way in which the data would be gathered could be varied depending on the product group and the reuse pathway. For example, it may be possible to oblige retail outlets which sell second hand goods to report annually on the quantity of goods sold. For car boot sales, it may make more sense to quantify the amount of reuse via indirect means. Efforts would also have to be made to ensure that the material counted as having been reused would have rightfully been prevented from the household waste stream.
Another option would be to include separate reuse targets in terms of either a) absolute quantities of municipal waste or b) percentages of municipal waste generated. The former would suffer, potentially, from the fact that municipal waste means different things in different countries, but if a definition could be standardised this might be a suitable approach.
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7.0 Material Recovery from MBT and
Incineration Facilities
Despite efforts to divert recyclables from the residual waste stream, a considerable amount of recyclable material still ends up in incineration and Mechanical Biological Treatment (MBT) plants all across Europe. The proportions of these materials that can be extracted from the residual stream during treatment vary greatly depending on the technologies used (and the detail of the configurations of those) and the properties of the materials in question. This section looks at recovery efficiencies from incinerators and MBT facilities and the material quality that can be achieved, focusing particularly on metals. It should be noted that this element of work was developed prior to the publication of the Commission’s revised package in December 2015.
This Section is comprised of the following sections:
Section 7.1 – presents the results of a detailed literature review which gathered information on the proportion of materials that can typically be recovered from the waste streams which pass through incinerators and MBT facilities;
Section 7.2 – reviews some of the issues around the quality of the material which is extracted from these residual waste treatment facilities; and
Section 7.3 – analyses the extent to which the inclusion of metals extracted from incinerator bottom ash will increase Member States’ reported municipal waste recycling rates. It also examines, based on the data contained in the European Reference Model on Municipal Waste Management, what materials currently extracted from MBT facilities are likely contributing to recycling rates (the model assumes that metals and plastics recovered from MBT can count towards the MSW recycling targets, but assumes that biowaste recovered from MBT is not counted).
7.1 Rates of Material Recovery
7.1.1 Metal Recovery from Incinerators
Bottom ashes from incineration plants typically contain metal scraps in the range of 8% to 18% and recovery of these metals is standard practice at most facilities.75,76,77 However,
75 Grosso M, Biganzoli L, and Rigamonti L (2012) A quantitative estimate of potential aluminium recovery from incineration bottom ashes, Resources, Conservation and Recycling, Vol.55, pp.1178–1184 76 Allegrini, E., Maresca, A., Olsson, M.E., Holtze, M.S., Boldrin, A., and Astrup, T.F. (2014) Quantification of the resource recovery potential of municipal solid waste incineration bottom ashes, Waste Management, Vol.34, No.9, pp.1627–1636 77 Bunge, R. (2015) Recovery of Metals from Waste Incinerator Bottom Ash, Institut für Umwelt und Verfahrenstechnik UMTEC, April 2015, http://umtec.hsr.ch/fileadmin/user_upload/umtec.hsr.ch/Dokumente/News/1504_Metals_from_MWIBA__R._Bunge.pdf
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recovery efficiencies vary greatly across different types of metals and depend largely on the extraction technologies being deployed.
Bottom ashes are, in addition to the ash from burnt materials, composed of a mix of incombustible materials such as sand, stone, glass, porcelain and metals. The metal fraction consists of ferrous metals, such as iron and steel, and non-ferrous metals, typically aluminium, but also copper, zinc and precious metals such as gold and silver. In a large number of European incineration plants, after recovery of some metals as noted above, the bottom ashes are reprocessed to be used as a secondary construction material, for example, in road construction, concrete production, and the repairing of dykes.78 In order to achieve a high quality material, the removal of metals is necessary, since if present in the end product they can expand and contract and make it unstable. The metals may also have value, but in any case, if they are sent for subsequent recycling (even at zero value) there is avoidance of disposal costs.
The bottom ash is typically extracted from the grate using a wet discharge before it is submitted to a dry treatment process. During reprocessing, ferrous metals are extracted magnetically while non-ferrous metals are recovered using an eddy current separator. Recovery rates for ferrous metals are typically reported at above 80%, while recovery efficiencies of non-ferrous metals can vary greatly.79 Secondary data on aluminium recovery, which typically makes up 60% of non-ferrous metals in bottom ashes, suggests recovery rates between 0% and 83%.80,81
The higher end of the range is typically achievable only in plants using state of the art extraction equipment, which is currently only installed in a few facilities in Europe. These facilities employ different processing techniques, designed to improve end product quality and metal recovery. One example is a dry extraction of bottom ashes from the grate in the incinerator, followed by a dry treatment process, which is employed in two Swiss EfW plants. This approach yields increased recovery rates as well as higher quality extracted metals: however, the technique results in high dust emissions from the mineral fraction and is, therefore, not currently widely employed. Another innovative approach removes the bottom ash by a wet discharge and then follows with a wet treatment process. This technique aims to improve the recyclability of the recovered metals and the quality of the end product. Examples of this process can be found in Belgium, the Netherlands, Germany, and Italy.82
78 Vehlow, J. and Seifert, H. (undated) Management of Residues from Waste-to-Energy Processes, Karlsruhe Institute of Technology, Institute for Technical Chemistry, www.ieabioenergytask36.org/vbulletin/attachment.php?attachmentid=298&d=1362675611 79 Allegrini, E., Maresca, A., Olsson, M.E., Holtze, M.S., Boldrin, A., and Astrup, T.F. (2014) Quantification of the resource recovery potential of municipal solid waste incineration bottom ashes, Waste Management, Vol.34, No.9, pp.1627–1636 80 Grosso M, Biganzoli L, and Rigamonti L (2012) A quantitative estimate of potential aluminium recovery from incineration bottom ashes, Resources, Conservation and Recycling, Vol.55, pp.1178–1184 81 Grosso M, Biganzoli L, and Rigamonti L (2012) A quantitative estimate of potential aluminium recovery from incineration bottom ashes, Resources, Conservation and Recycling, Vol.55, pp.1178–1184 82 Waste Management World, Accessed 02/10/2015, http://www.waste-management-world.com/articles/print/volume-12/issue-6/features/rising-from-the-waste-to-energy-ashes.html
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The extraction of non-ferrous metals requires more complex recovery equipment and is generally more challenging. Non-ferrous metals are also subject to partial volatilisation during combustion and oxidisation of thinner aluminium scraps, such as foils, which reduces the recoverable mass.83 Table 7-1 presents a summary of findings from various studies that have reported on metal recovery rates from incineration facilities.
Table 7-1: Metal Recovery Efficiencies from Incinerators
Data Source Technology Recovery Rate (%)1
Lower Limit Upper Limit
Aluminium
France Aluminium Recyclage (2006) Technology not stipulated - 35%
Association of Incinerators NL (2006)
Technology not stipulated - 48.2%
Muchova and Rem (2007)
State of the art 9% 28%
Pilot plant AEB - 80%
State of the art (NL) 2-20mm 7% 45%
State of the art (NL) >20mm - 83%
Manders (2008)
Pilot plant AEB 2-20mm 83% 87%
Multistep unit 55% 65%
Advanced design - 70%
Pruvost (2009) State of the art (FR) 65% 70%
Ferrous Metals
Muchova and Rem (2008) Technology not stipulated - 83%
Association of Incinerators NL (2006)
Technology not stipulated - 82.5%2
Lamers (2008) Technology not stipulated - 57%2
Bunge (2015)3 Technology not stipulated 85% 95%
Notes:
1. Recovered metal/metal fed into furnace.
2. Recovered metal/metal in bottom ashes.
3. Bunge, R. (2015) Recovery of Metals from Waste Incinerator Bottom Ash, Institut für Umwelt und Verfahrenstechnik UMTEC, April 2015, http://umtec.hsr.ch/fileadmin/user_upload/umtec.hsr.ch/Dokumente/News/1504_Metals_from_MWIBA__R._Bunge.pdf
Source: Adapted from Grosso M, Biganzoli L, and Rigamonti L (2012) A Quantitative Estimate of Potential Aluminium Recovery from Incineration Bottom Ashes, Resources, Conservation and Recycling, Vol.55, pp.1178–1184
7.1.2 Metal Recovery from MBT Plants
An MBT plant consists of a mechanical treatment stage and a biological treatment stage. During mechanical treatment, recyclates are removed from the waste received using a
83 François Pruvost (2011), CEWEP-EAA Seminar, http://cewep.eu/media/cewep.eu/org/med_666/748_03_francois_pruvost.pdf
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range of sorting technologies such as screens, ballistic separation, magnets, eddy current separators and optical sorters. Some plants do most of this prior to the biological treatment phase, whilst others do more of it after the treatment phase, and some may do both (much depends on the objectives of the facility, and the nature of the biological treatment step).
Metal recovery is achieved using the same magnetic and eddy current techniques as are used in incineration plants. Recovery rates from MBT plants vary greatly as shown in Table 7-2.
Table 7-2: Metal Recovery Efficiencies Achieved Through Mechanical Sorting at MBT Plants
Source of Data Technology Type Metal Recovery Rate (%)
Lower Limit Upper Limit
Montejo et al. (2013) 1 Study of 8 MBT plants in Spain
Ferrous 35% 84%
Non-ferrous 33% 95%
Cimpan et al. (2015)2
Mainly manual sorting
Ferrous 40% 80%
Non-ferrous 30% 60%
Automatic and manual sorting
Ferrous 44% 88%
Non-ferrous 35% 70%
State of the art, automatic sorting
Ferrous 48% 95%
Non-ferrous 40% 80%
Spitzer and Tustin (2009)3 Technology not stipulated
Ferrous 82%
Non-ferrous 86%
Dipl.-Ing. Adele Clausen and Prof. Dr.-Ing. Thomas Pretz (2012)4
Advanced automated sorting
Ferrous - 70%
Non-Ferrous - 95%
Notes:
1. Based on experimental data. Montejo, C., Tonini, D., Márquez, M. del C., and Fruergaard Astrup, T. (2013) Mechanical–biological treatment: Performance and potentials. An LCA of 8 MBT plants including waste characterization, Journal of Environmental Management, Vol.128, pp.661–673
2. Upper limits refer to plants operating at designated capacity, while lower limits simulate a plant running above designated capacity, which reduces recovery efficiency. Cimpan, C., Maul, A., Wenzel, H., and Pretz, T. (2015) Techno-economic assessment of central sorting at material recovery facilities – the case of lightweight packaging waste, Journal of Cleaner Production.
3. Refers to ‘typical recovery rate’. Spitzer, J., and Tustin, J. IEA Bioenergy Annual Report 2009.
4. ThDipl.-Ing. Adele Clausen, and Prof. Dr.-Ing. Thomas Pretz (2012) Advanced Automated Sorting & Future Waste Management - Perspectives for Resource and Carbon Efficiency, Paper Given at 2nd Waste & Climate Beacon Conference, Copenhagen, 20 April 2012
7.1.3 Extraction of Other Materials
Bottom ash is used widely throughout Europe as a secondary aggregate in concrete production or road construction. As noted above, metals can expand if present in bottom ashes used in road construction or concrete production, and the recovery of metals is therefore a prerequisite for the safe reuse of bottom ashes and is required by legislation. Recovery of other materials such as glass, although potentially possible, is not legally required for the recycling of bottom ashes and is, therefore, far less common (and the market value of the material would not make its recovery very viable).
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Although recovery from MBT plants can involve a wide range of materials, the high value of metals and relatively simple technology required for its recovery means most MBT plants are programmed to optimise metal recovery. The extraction of other materials will largely be driven by the following concerns:
1) The input specifications for the use of RDF in certain facilities may require that plastics are removed in order to reduce the amount of chlorine in the material;
2) The price differential between the amount paid to send the RDF or residues to incineration / landfill and the cost of extracting and passing on the recyclables; and
3) Whether there is a market for the recyclables which have been extracted.
In countries where the costs of landfill / incineration are high it would make sense for an operator to extract as much material as possible for recycling and pass this on as cheaply as possible (assuming that a market existed for these materials). Even if it means paying somebody to take the material it may still be cheaper than having to deal with the RDF / residues. The challenge is finding an end market for these materials, particularly when the cost of primary materials is relatively low. A wide range of techniques can be used to segregate recyclable materials from a residual waste stream. A summary of different waste separation techniques is shown in Table 7-3.
Table 7-3: MBT Separation Techniques
Separation Technique Separation Property Materials Targeted Key Concerns
Trommels and Screens Size
Oversize – paper, plastic
Small – organics, glass, fines
Air containment and cleaning
Manual Separation Visual Examination Plastics, contaminants, oversize
Ethics of role, Health and Safety issues
Magnetic Separation Magnetic Properties Ferrous metals Proven technique
Eddy Current Separation Electrical Conductivity Non-ferrous metals Proven technique
Wet Separation Technology
Differential Densities Floats - Plastics, organics
Sinks - stones, glass
Produces wet waste streams
Air Classification Weight Light – plastics, paper
Heavy – stones, glass Air cleaning
Ballistic Separation Density and Elasticity Light – plastics, paper
Heavy – stones, glass Rates of throughput
Optical Separation Diffraction Specific plastic polymers Rates of throughput
Source: Defra (2013) Mechanical Biological Treatment of Municipal Solid Waste, 2013, www.gov.uk/government/uploads/system/uploads/attachment_data/file/221039/pb13890-treatment-solid-waste.pdf
Depending on the configuration of the MBT plant, materials such as glass, plastics, textiles, paper and card may be extracted during the mechanical stage of the MBT process, with glass (and other inert materials) and plastics being the most commonly extracted material after metal.
The recovery rates for non-metal materials from MBT plants will depend on the configuration of the plant and the technologies installed, and so, vary greatly across plants. The available data on recovery efficiencies is limited: however, a range of 30% to 50% is suggested for plastics, as shown in Table 7-4. Eunomia’s own investigations with operators
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of MBT facilities indicate that the extraction rates at facilities with the capacity to remove plastics can be very high: however, once the proportion of the plastics that have a reasonable prospect of finding an end market have been extracted, then the arguments for more intensive extraction come down to whether there is a need for further plastics removal from the output streams (for example, to reduce chlorine content in solid recovered fuel, or to reduce its fossil carbon content).
Table 7-4: Plastic Recovery from MBT Plants
Source of Data Technology Recovery Rate (%)
AEA (2009)84 Higher recovery rate 50%
Dipl.-Ing. Adele Clausen and Prof. Dr.-Ing. Thomas Pretz (2012)
Advanced automated sorting 30%
There is growing interest in the potential for extracting paper of recyclable quality from MBT systems: much is thought to depend on how efficiently the recycling service (before the MBT plant) removes food waste from the residual waste stream. Where the food waste content of residual waste is lowered, then the cross-contamination and wetting of paper and card by food wastes may be reduced to levels that allow for the extraction of marketable outputs.
7.2 Material Quality
The quality of the metal recovered from incinerators and MBT facilities affects the price the plant operators obtain for the material and it is, therefore, an important consideration. Recyclables recovered from incineration and MBT processes are typically of a lower quality than materials derived from source separated household collections.85 This section examines some of the key issues in relation to both incinerators and MBT facilities.
7.2.1 Metals Recovered from Incinerators
Metals passing through incinerators undergo, to varying degrees, a number of physical and chemical transformations. The extent of the transformations depends on the physical and chemical structures of the metals themselves and how they tolerate the high temperatures to which they are exposed during the incineration process. The fates of four different ‘groups’ of metals are described below:
1) “Iron, copper, brass, nickel, chromium and gold are transferred almost entirely to the bottom ash. As they have melting temperatures above those normally encountered in MWI, the bulk of these metals will not engage in chemical reactions
84 Judith Bates, AEA (2009) Comparing the Environmental Impacts of Residual Waste Management Options, paper given at IEA Bioenergy Multi- task Conference, Vancouver, August 2009, http://www.iea-biogas.net/files/daten-redaktion/download/publications/workshop/3/Vancouver09_Bates_Judith.pdf 85 Defra (2007) Mechanical Biological Treatment of Municipal Solid Waste, 2007, http://webarchive.nationalarchives.gov.uk/20130402151656/http:/archive.defra.gov.uk/environment/waste/residual/newtech/documents/mbt.pdf
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except for their surfaces, which may become oxidized or corroded. Since these metals are prevalent in the waste in their native form, the stoking action of the grate will cause a downward segregation from the surrounding waste because of their high density.
2) Aluminum melts at around 660°C but is protected from progressive oxidation by a tenacious aluminum oxide skin that encloses the melt. Molten aluminum droplets trickle through the firebed onto the grate which is cooled by the inflowing air. Here the aluminum melt solidifies, resulting in odd shaped “nuggets” [Figure 7-1]. In addition to oxidation, some aluminum is lost by the formation of aluminum nitride, resulting from the reaction of nitrogen from air with aluminum metal at around 900°C.
3) Zinc and lead are transferred to more or less equal fractions into the bottom ash and the fly ash. Most of the “native” zinc that ends up in the bottom ash is present in brass, which has a higher melting temperature that zinc itself. Much of the lead is present not as native metal but in chemical compounds such as lead crystal which end up in the BA. Since zinc and lead melt at incinerator temperature, they engage in thermochemical corrosion reactions, for example by chloride formation, and are hence transferred into the filter ash.
4) All of the mercury and most of the cadmium are transferred to the flue gas and either end up in the fly ash (cadmium) or in dedicated washers and filters (mercury). Some cadmium is trapped in rechargeable batteries which, by virtue of their high density, segregate through of the firebed onto the grate and remain largely intact [Figure 7-1]. Some cadmium is also encountered as anti-corrosion paint or colored glazing on pottery and consequently ends up in the bottom ash.”86
Oxidation of metals during the incineration process is more pronounced for certain metals (e.g. copper and steel). Large pieces of metal which have a small surface area relative to their total mass will experience limited oxidation, whereas small thin pieces of metal with large surface areas will experience far more pronounced, or even complete, oxidation. It has been estimated, for example, that a third of the iron and aluminium passing through incinerators is lost as a result of thermal oxidation. Experiments with aluminium cans have also shown similar loss rates. In addition to oxidation, the plating of steel with copper is another commonly cited issue.87 The presence of copper can compromise the quality of steel scrap by altering its chemical and physical properties in a number of important ways.88
86 Bunge, R. (2015) Recovery of Metals from Waste Incinerator Bottom Ash, Institut für Umwelt und Verfahrenstechnik UMTEC, April 2015, http://umtec.hsr.ch/fileadmin/user_upload/umtec.hsr.ch/Dokumente/News/1504_Metals_from_MWIBA__R._Bunge.pdf, p. 13 87 Bunge, R. (2015) Recovery of Metals from Waste Incinerator Bottom Ash, Institut für Umwelt und Verfahrenstechnik UMTEC, April 2015, http://umtec.hsr.ch/fileadmin/user_upload/umtec.hsr.ch/Dokumente/News/1504_Metals_from_MWIBA__R._Bunge.pdf, p. 15/16 88 Savo, L., Volkova, E. and Janke, D. (2003) Copper and Tin in Steel Scrap Recycling, Materials and Geoenvironment, Vol. 50, No. 3, pp. 627-640
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Figure 7-1: Examples of Metals Extracted from Incinerator Bottom Ash
Copper showing signs of surface oxidation Brass mountings and fittings
Solidified ‘nugget’ of melted aluminium Recovered intact batteries
Source: Bunge, R. (2015) Recovery of Metals from Waste Incinerator Bottom Ash, Institut für Umwelt und Verfahrenstechnik UMTEC, April 2015, http://umtec.hsr.ch/fileadmin/user_upload/umtec.hsr.ch/Dokumente/News/1504_Metals_from_MWIBA__R._Bunge.pdf, p. 13/14
The above demonstrates that metals are lost through oxidation and chemical transformation. Oxidation and plating with other metals means that their purity will seldom be at the same level as that of separately collected materials that have not been exposed to the extreme temperatures typical of incinerators. As such, the price paid for recovered ferrous and non-ferrous metals is typically lower. For example, Professor Rainer Bunge from the Swiss Institut für Umwelt und Verfahrenstechnik reports that:
“The sales price of the NF [non-ferrous metal] is generally linked to the metal prices published by the LME (London Metal Exchange). But since the concentrate needs to be further processed (in sink/float plants and smelters) to deliver the metals in the form of bullion, the price actually paid by the sink/float plants or smelters for the
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metal content of the NF concentrate is only approximately 60% of the LME notation.”89
Experts consulted by Eunomia confirmed that metal from incineration bottom ash (IBA) is very variable in quality. The variation derives from differences in type of incinerator and the secondary cleaning that is carried out. Recovered metals can be blended with other metals as part of large batches produced to different specifications depending on the grade of material to be made in the smelting process.
The British Metal Recycling Association (BMRA) has developed separate grades for metals extracted from IBA. Grade 6a refers to recovered metals which have been baled, whilst Grade 6b refers to loose materials (i.e. unbaled). It is reported that these grades of material are not (at the time of writing) currently being bought by the UK steel industry due to slowdown in the global market and falling prices (which mean that smelters can be more selective about their input materials).90 It was suggested in an interview that scrap dealers in the United Kingdom currently buy the extracted metals for onward sale. It is not clear to whom the material is sold, although it was speculated that it may either be trommelled then baled for export or else potentially mixed in with other material and sold as one of the most common scrap grades, Grade 3b. It was acknowledged that the second option was a rather contentious accusation; however, it was felt the current pressures in the market are such that people may be willing to move material in this way and take advantage of the higher price being paid for Grade 3b scrap relative to Grades 6a or 6b.
7.2.2 Materials Recovered from MBT Facilities
A study which interviewed five plant operators in the United Kingdom reported that:
“Operators reported that the relatively low quality of non-ferrous outputs from MBTs was reflected in the lower prices obtained from metal recyclers. Whilst exact prices are commercially sensitive, a general view was that non-ferrous metal from an MBT would typically command a price of between £200 and £300 per tonne, whereas non-ferrous metal from a dry MRF [Material Recovery Facility] may command a price between £700 and £800 per tonne, a differential of up to £600 per tonne. Operators also commented that the market for clean material was more stable, since if metals recyclers reduce their purchasing requirements due to falls in end-user demand, it would inevitably be the lower quality materials which were rejected first.” 91
89 Bunge, R. (2015) Recovery of Metals from Waste Incinerator Bottom Ash, Institut für Umwelt und Verfahrenstechnik UMTEC, April 2015, http://umtec.hsr.ch/fileadmin/user_upload/umtec.hsr.ch/Dokumente/News/1504_Metals_from_MWIBA__R._Bunge.pdf 90 Let’s Recycle (2015) Recyclers to Focus on Export Market for Metals, Date Published: 20th October 2015, Date Accessed: 20th October, Available at: www.letsrecycle.com/news/latest-news/recyclers-to-focus-on-export-market-for-metals/ 91 WRAP (2012) Recovery of laminated packaging from black bag waste, accessed 2 October 2015, http://www.wrap.org.uk/sites/files/wrap/Recovery%20of%20laminated%20packaging%20from%20black%20bag%20waste.pdf
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Recovered glass is typically highly contaminated, especially by the organic fraction of the MBT input, reducing the quality of the material to the extent that it is unusual for MBT recovered glass to achieve sufficient quality to be sold in re-melt applications, and meaning that it is often rejected by recyclers.92 Non-manual recovery of glass is usually by size and density separation, which equally selects non-recyclable glass, bricks, sand and stones.93 Glass recovered from MBT is, therefore, usually used as aggregate. However, given the cost of disposing of the material in some countries, there may be a financial incentive to extract it and produce an aggregate product even if it does not have a high market value.
The quality of other materials, including plastics, paper and textiles is also typically low. In the UK, the Department for Environment, Forestry, and Rural Affairs (Defra) reports that where these materials are recovered, the recyclate is unlikely to receive an income.94 In the case of paper, manual or more complex sorting technologies can be employed to recover this material. However, the quality is likely to be lower and the number of off-takers fewer than for source segregated paper, resulting in lower prices. Paper recovered from refuse sorting stations is considered unsuitable for use in the paper industry according to a standard supported by the recycling sector and trade associations. The uncertainty of the market means that many MBT operators prefer to use the paper as part of the high calorific value fraction used as refuse derived fuel (RDF), where it contributes to the renewable component of the fuel.95 Segregated plastics recovered without the use of advanced optical sorting technologies will generally always be mixed plastics. One source reported a material purity of 90% of plastics recovered from MBT plants with advanced automated sorting technologies.96
The issue of including ORO in Member State recycling targets was discussed in Section 5.6.1. These concerns were based on the evidence that emerged from the JRC’s research that was conducted over a number of years. The JRC’s second working document on the end-of-waste criteria for biodegradable waste clearly identifies substantial concerns in relation to the compost materials being produced by MBT facilities. The JRC noted the following with respect to the concentration of heavy metals in a range of compost / digestion materials:
“Generally, the concentrations of heavy metals are in the same range for most [compost] samples, except for the MBT samples that display large concentration
92 Dias, N., Garrinhas, I., Maximo, A., Belo, N., Roque, P., and Carvalho, M.T. (2015) Recovery of glass from the inert fraction refused by MBT plants in a pilot plant, Waste Management 93 Cook, E., Wagland, S., and Coulon, F. (2015) Investigation into the non-biological outputs of mechanical–biological treatment facilities, Waste Management, Vol. 46, pp. 212-226 94 Defra (2013) Mechanical Biological Treatment of Municipal Solid Waste, 2013, https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/221039/pb13890-treatment-solid-waste.pdf 95 Defra (2007) Mechanical Biological Treatment of Municipal Solid Waste, 2007, http://webarchive.nationalarchives.gov.uk/20130402151656/http:/archive.defra.gov.uk/environment/waste/residual/newtech/documents/mbt.pdf 96 Dipl.-Ing. Adele Clausen, and Prof. Dr.-Ing. Thomas Pretz (2012) Advanced automated sorting & future waste management - Perspectives for resource and carbon efficiency, paper given at 2nd Waste & Climate Beacon Conference, Copenhagen, 20 April 2012
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peaks. More specifically, it is noted that the highest concentrations of heavy metals are encountered in the MBT compost samples, for nearly all metals.”97
“With the currently proposed heavy metal concentrations for compost/digestate […] several MBT compost samples exceed proposed limits for Cu (100 mg/kg dry matter), Pb (120 mg/kg dry matter) and Zn (400 mg/kg dry matter).”98
With respect to organic pollutants the following comments by the JRC are instructive:
“It is noted that the PCB concentration is highest in both MBT samples and one green waste compost sample (not confirmed by other sample). Dioxin concentration is highest in both MBT samples and digestate samples.”99
“Octa-formulated PBDE concentrations are visibly much higher for the MBT samples than for the other samples and deca-formulated PBDE samples are undoubtedly much higher for the MBT samples and sewage sludge compost samples than for any of the other samples.”100
“… polycyclic musk concentrations are very high in both the sewage sludge compost samples and MBT samples. Concentrations were below the detection limit or absent in the other [compost] samples.”101
“… fluorosurfactants appear in all analyzed materials. Again, it is noted that the highest concentrations are encountered in all sewage sludge compost samples and all but one MBT compost sample.”102
Based on the above evidence the JRC concluded by saying that:
“MBT compost samples contain very high concentrations of heavy metals and organic pollutants, compared to the other sampled materials. This was confirmed by the measurements of both the JRC sample and the sample provided by the plant.”103
In light of this, the JRC’s second working document recommended that:
“…based on the available preliminary data, and in respect of the precautionary principle, it is recommended that MBT compost and digestate as well as sewage sludge compost and digestate are to be excluded from eligibility for end of waste status.”104
The JRC published a third working document in August 2012, which proposed allowing a broad range of input materials, including mixed municipal solid waste, to be used for
97 European Commission Joint Research Centre (2011) Technical Report for End-of-waste Criteria for Biodegradable Waste Subject to Biological Treatment, Second Working Document, October 2011, p. 72 98 Ibid., p. 72 99 Ibid., p. 73 100 Ibid., p. 74 101 Ibid., p. 74 102 Ibid., p. 75 103 Ibid., p. 76 104 Ibid., p. 76
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composting provided that strict output quality criteria were respected.105 The JRC’s final report on the subject, published in early 2014, notes that:
“The majority of Member States report a historical market rejection of the separated organic fraction obtained from MBT for use as compost on (agricultural) land. Up to the 80's or 90's of the last century, most of the MBT output was characterized by a high content of heavy metals and visually noticeable physical impurities, which often led to public repulsion. In some cases, this has led to a ban of such material in agriculture and to a shift of the outlets for MBT stabilized materials to landfilling/incineration, often with a parallel establishment of a separate collection and composting/digestion system for organic waste (e.g. Germany). In other cases, this has led to stricter legal requirements for the material, the introduction of a partial source separation of MSW, such as the separate collection of glass and WEEE, and an upgrading of the MBT installations (e.g. France).”106
In the JRC’s final report it was emphasised that the experts of the technical working group were divided about whether ORO should be allowed to achieved end-of-waste status. Despite the known uncertainty in this area, the JRC only included samples from two MBT facilities in their study. This meant that they were only able to draw illustrative conclusions. With the small sample size in mind, it is still instructive to outline the key findings. As part of the analysis, it was found that the organic pollutants were below the threshold limits set by the study. The findings in relation to heavy metals and physical impurities give greater cause for concern:
“The results for MBT compost from the JSAC seem to converge with the external data. The large French Ineris database (247 samples) shows that Cr, Ni and Zn limits are generally met. However, 8.0%, 12.4 % and 19.4% of the samples exceed the Cu, Cd and Pb limits, respectively, in line with the findings from the current JRC study. From the Spanish MBT data it was derived that none of the samples would meet all criteria, although it should be emphasized that the size of the Spanish dataset is much smaller than the Ineris dataset (only 12 samples). Nevertheless, based on MBT compost data over the last decade (2003-2012), it was noticed that only 2 out of 48 Spanish samples met all proposed limits for heavy metals.”107
“Both the extensive French data and limited Spanish data indicate that a large majority of MBT composts is not able to meet the proposed [physical impurities] limit values. More than 90% of the samples fail the proposed criteria. Although the measurement method may partially explain this figure (e.g. bleach determination in France), it is believed that a combination of consumer attitude and technology are the main responsible factors. As such, it is noted that large
105 European Commission Joint Research Centre (2014) Technical Report for End-of-waste Criteria for Biodegradable Waste Subject to Biological Treatment (Compost and Digestate): Technical Proposal, January 2014, http://ipts.jrc.ec.europa.eu/publications/pub.cfm?id=6869,p. 9 106 Ibid. p. 14 107 Ibid. p. 85
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fractions of the physical impurities in French MBT compost consist of glass. This suggests that glass enters the mixed MSW chain rather than being recycled through the available glass and WEEE33 collection systems, and that the ensuing mechanical separation of the mixed MSW has not been able to remove all of this glass. It also appeared that huge differences existed between the physical impurities levels of different MBT installations.”108
Research conducted in England has also raised some concerns and uncertainty about the quality of the ORO (in the UK the organic-rich output is referred to as compost like output, or CLO). As part of the research undertaken, the inputs and corresponding outputs of four MBT plants were assessed. Following detailed sampling and analysis over a number of months the Environment Agency stated:
“The variety of processes used in MBT/MHT plants and the variability in the input feedstocks leads to a significant variability in the form and characteristics of CLO, both between and within such plants. This variability, in terms of the physical and chemical characteristics of the CLO, makes it especially difficult to assess the potential environmental and human health risks following CLO application to soils.”109
The study also reports the following:
“Samples from the four sites were analysed for a suite of chemicals: perfluorocarbons and triclosan; dioxins and furans; metals and other elements; polycyclic aromatic hydrocarbons; hydrocarbons; perchlorinated biphenyls; E. coli and Salmonella.
These analyses revealed that:
no PCBs were detected in any samples from any sites;
only one site registered Salmonella; all sites registered E. coli at least once;
the presence of hydrocarbons, particularly longer chain hydrocarbons, was unexpectedly high, although the concentrations are below the derived published PNECs [predicted no effect concentrations];
published PNECs of these hydrocarbons are widely acknowledged to be of low reliability, so the concentrations of these chemicals in CLO may still be of concern;
results for all other chemical groups analysed in the samples showed wide variability between elements and between sites.”110
The study also investigated the potential for nitrogen (N) and phosphorus (P) leaching resulting from the application of CLO to land. It was found that “CLOs with a high N content
108 Ibid. p. 89 109 United Kingdom Environment Agency (2009) Assessment of MBT Input and Output Quality, December 2009, www.gov.uk/government/uploads/.../scho1209brqg-e-e.pdf, p. 110 Ibid., p. 76
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do increase the risk of higher N leaching”.111 In contrast, based on the sites studied it was reported that the leaching of P did not pose an increased risk.
The above reiterates already known concerns associated with the ORO from MBT facilities. Despite this, some Member States are counting (or are intending to count) this material within their recycling rates (it is not obvious how, for example, the calculation is made, e.g. how the output ORO is linked back to an input quantity, if at all), whereas other Member States explicitly exclude it (and if they included it, they would report higher recycling rates). This remains a problematic area, and points to the need for clarification at EU level to ensure comparability in reported performance.
7.3 Reporting Against Recycling Targets
7.3.1 Metals Recovered from Incinerators
While most Member States seem not to include the quantity of recovered metals in their municipal waste recycling targets (in line with current European guidelines), there appears to be more ambiguity as to whether these metals can count towards the packaging waste targets.
Data on the amount of municipal waste assumed to be entering incinerators was extracted from the Municipal Waste Model in order to assess what impact the recovery of metals from incinerators may have on the municipal waste recycling targets. Due to the compositional data provided by Member States as part of the development of the Municipal Waste Model it is not possible to accurately distinguish between ferrous and non-ferrous metals.112 The analysis presented here, therefore, looks at metals as an overall category and has assumed that either 60% (low scenario) or 80% (high scenario) of the metals entering incinerators will be able to be extracted and sent for recycling.
To provide a comparison, the results for two scenarios have been assessed:113
Full implementation scenario – this assumes that all Member States achieve the existing 50% MSW preparation for reuse and recycling target; and
70% MSW preparation for reuse / recycling scenario – this scenario sets a 70% target to be achieved by Member States in 2030 (with five year derogations for Member States recycling less than 20% of their MSW in 2013).
Table 7-5 shows the quantity of material that could potentially – based on the input data and assumptions set out in the Municipal Waste Model114 – be extracted from incinerators
111 Ibid., p. 78 112 See Appendix 1 of the following report Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission Directorate-General for the Environment, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip 113 see Section 3 of Appendix A.1.0 for more details on each scenario. 114 Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission Directorate-General for the Environment, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip
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in 2035. The figures are shown for 2035 as this is the point by which all Member States will have achieved the 70% preparation for reuse / recycling target under the second scenario. The full implementation scenario only sees Member States moving towards the existing 50% target set out in the Waste Framework Directive by 2020. There will, therefore, be more material going to residual waste treatment and disposal under full implementation than under the scenario which sees recycling rates for most Member States increase to 70% by 2030. As such, one would expect more metals to be extracted from incinerators under the full implementation scenario. This is clearly shown in Table 7-5, where it can be seen that across the EU28 somewhere between an estimated 1.6 million tonnes (assuming extraction efficiencies of 60%) and 2.1 million tonnes (80% extraction assumed) of metals could be extracted for recycling in 2035. For the 70% MSW preparation for reuse/recycling scenario this range is somewhat lower at 974 thousand tonnes to 1.3 million tonnes.
It is not known how many, if any, Member States currently include metal extracted from incinerators as counting towards their municipal waste recycling targets. Figure 7-2 shows the extent to which the tonnages reported in Table 7-5 would help to increase Member States’ municipal waste recycling rates in 2035. It is clear that the countries which currently have a substantial amount of incineration capacity will experience the greatest benefit from including these materials in their recycling targets.
According to the data contained in the Municipal Waste Model, Denmark would stand to benefit the most, with municipal recycling rates increasing by almost 2% under the full implementation scenario. Germany comes in second with recycling levels estimated to increase by up to 1.3%, followed by France (1.3%), the Netherlands (1.1%), then Austria (0.85%). Where municipal preparation for reuse / recycling rates are increased to 70% the benefit of incorporating these recovered metals in the targets is diminished due to the fact that less residual waste is being produced and treated at incinerators. For all countries, other than Denmark, the inclusion of these materials will add less than 1% to the overall recycling target.
Table 7-5: Quantity of Metals Recovered from EU Incinerators Under Two Different Scenarios and Assumptions of ‘Low’ and ‘High’ Extraction Efficiencies (2035)
Member State
60% of Metals Entering Incinerators Recovered for Recycling
80% of Metals Entering Incinerators Recovered for Recycling
Full Implementation
Scenario
70% MSW Preparation for
Reuse / Recycling Scenario
Full Implementation
Scenario
70% MSW Preparation for
Reuse / Recycling Scenario
thousand tonnes
Austria 38 22 51 30
Belgium 36 17 48 22
Bulgaria 0 0 0 0
Croatia 0 0 0 0
Cyprus 0 0 0 0
Czech Republic 31 19 41 26
Denmark 71 63 95 84
Estonia 3 2 4 2
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Member State
60% of Metals Entering Incinerators Recovered for Recycling
80% of Metals Entering Incinerators Recovered for Recycling
Full Implementation
Scenario
70% MSW Preparation for
Reuse / Recycling Scenario
Full Implementation
Scenario
70% MSW Preparation for
Reuse / Recycling Scenario
thousand tonnes
Finland 9 6 12 8
France 377 171 503 228
Germany 478 347 637 463
Greece 3 1 4 1
Hungary 23 14 31 19
Ireland 7 7 10 9
Italy 79 47 105 63
Latvia 2 1 2 1
Lithuania 2 2 3 2
Luxembourg 1 1 2 1
Malta 0 0 0 0
Netherlands 96 37 127 50
Poland 68 32 91 43
Portugal 13 7 18 9
Romania 0 0 0 0
Slovakia 17 9 23 12
Slovenia 0 0 1 0
Spain 7 6 10 8
Sweden 37 36 49 49
United Kingdom 156 126 208 167
EU28 1,555 974 2,074 1,299
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Figure 7-2: Impact on Recycling Rates in 2035
0.00%
0.50%
1.00%
1.50%
2.00%
BulgariaCroatia
Cyprus
Malta
Romania
Spain
Slovenia
Greece
Lithuania
Latvia
Ireland
Italy
Portugal
LuxembourgFinland
United Kingdom
Estonia
Hungary
Czech Republic
Poland
Belgium
Sweden
Slovakia
Austria
Netherlands
France
Germany
Denmark
0.00%
0.50%
1.00%
1.50%
2.00%
BulgariaCroatia
Cyprus
Malta
Romania
Spain
Slovenia
Greece
Lithuania
Latvia
Ireland
Italy
Portugal
LuxembourgFinland
United Kingdom
Estonia
Hungary
Czech Republic
Poland
Belgium
Sweden
Slovakia
Austria
Netherlands
France
Germany
Denmark
Full Implementation Scenario 70% MSW Preparation for Reuse / Recycling Scenario
Ass
um
ed 8
0%
Ext
ract
ion
of
Met
als
Ass
um
ed 6
0%
Ext
ract
ion
of
Me
tals
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As can be seen in Table 7-6, the majority of Member States for which data is available include metals recovered from incineration and MBT facilities when calculating their progress towards the packaging recycling targets. Some Member States may not include output from either incinerators or MBT plants due to materials not being recovered at all, or being recovered at very low rates (e.g. Greece and Romania have very limited incineration capacity at present). Out of the 14 countries considered, only Greece and Romania do not take metal recovery from either EfW or MBT plants into account. The data presented in Table 7-6 was obtained as part of an independent research task undertaken by Eunomia and it has not been possible to confirm the practices of the remaining Member States. However, from this sample it would appear that the majority of Member States that make regular use of incineration and MBT technologies to treat their waste will be including recovered materials in their recycling targets.
Table 7-6: Use of Recovered Metals in Reporting Against the Packaging Waste Recycling Targets
Member State Metals Recovered from Incinerators
Included in Recycling Target
Metals Recovered from MBT Included in Recycling
Target
Austria Yes Yes
Belgium Yes Yes
Denmark Yes Yes
Estonia Yes Yes
France Yes Yes
Germany Yes Yes
Greece No No
Italy Yes Yes
Netherlands Yes Yes
Poland No (considered too low to be quantified) Yes
Portugal Yes Yes
Romania No incineration of MSW No
Spain Yes Yes
UK Yes Yes
Source: Eunomia Internal Data
7.3.2 Materials Recovered from MBT Facilities
Many Member States already appear to include materials extracted from MBT plants in their recycling targets. The Municipal Waste Model, therefore, automatically attributes any materials recovered from MBT facilities to the national recycling targets of all 28 Member States. The model identifies five different types of MBT facilities and assumes the same material recovery rates from these facilities across all Member States. The assumed material recovery rates are shown in Table 7-7. It is evident that the 10% limit set for plastics is lower than the rates cited in Table 7-4. It is acknowledged that higher recovery rates for plastics may be achievable in practice (e.g. through manual sorting) but that the low value of the final product means that the economics of sorting do not currently make it viable to separate out more materials.
Table 7-7 also shows that no account has been made for the recovery of bio-wastes from MBT plants in the Municipal Waste Model. This was done in the light of the on-going JRC
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work at the time of developing the model and the clear evidence suggesting that compost outputs from these facilities, unless very carefully controlled – both in terms of input material and sorting/processing technologies – may result in unacceptable risks to human health and the environment (see discussion in Section 7.2.2). However, current rules allow an increasing number of Member States to spread the compost like output derived from MBT plants on land and count this towards their recycling targets. This will no doubt increase the volume of material that is effectively being recycled in these countries but is something which has not been considered as part of the technical analysis undertaken for this project (including the supplement to the impact assessment).
It is understood that a number of Member States are operating plants which are being classified as MBT facilities but which don’t have the biological treatment element. These facilities are effectively operating as residual waste sorting facilities, and are therefore also focused on pulling out other recyclables such as paper/card glass etc. The recovery rates in Table 7-7 may therefore underestimate the amount of material being captured from these types of facilities in countries such as Bulgaria.
Table 7-7: Assumed Rate of Material Recovery from MBT Facilities in the Municipal Waste Model
Type of MBT Facility Paper /
Cardboard Metals Plastics
Batteries and accumulators
MBT 1 - Biostabilisation 0% 63% 10% 70%
MBT 2 - Biodrying no plastics recycling 0% 63% 0% 70%
MBT 3 - Biodrying with plastics recycling 0% 63% 10% 70%
MBT 4 - AD based 0% 63% 10% 70%
MBT 5 - basic sorting + energy generation 20% 63% 10% 63%
Source: Appendix 6 of Eunomia Research & Consulting, and Copenhagen Resource Institute (2014) Development of a Modelling Tool on Waste Generation and Management, Report for European Commission Directorate-General for the Environment, February 2014, http://ec.europa.eu/environment/waste/pdf/waste-generation-management-model.zip
Based on the material flows assumed to be entering MBT facilities in the Municipal Waste Model it is possible to estimate the amount of material being extracted under the same two scenarios discussed above. The volumes of materials being recovered for recycling are presented in Table 7-8. As above, these figures are the estimates for 2035, and based on the assumption that all Member States will have achieved the 70% MSW preparation for reuse / recycling target by this point. As less residual waste is being produced under the 70% recycling scenario, smaller volumes of material are being extracted from MBT facilities therefore contributing less to the overall achievement of the target.
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Table 7-8: Quantity of Materials Recovered from EU Incinerators Under Two Different Scenarios (2035)
Member State
Full Implementation Scenario 70% MSW Preparation for Reuse /
Recycling Scenario
Pap
er
/
Car
db
oar
d
Me
tals
Pla
stic
s
Bat
teri
es
and
accu
mu
lato
rs
Pap
er
/
Car
db
oar
d
Me
tals
Pla
stic
s
Bat
teri
es
and
accu
mu
lato
rs
Austria 2 16 13 0 1 6 7 0
Belgium 2 1 0 0 1 0 0 0
Bulgaria 0 0 4 0 0 0 2 0
Croatia 0 10 24 0 0 4 11 0
Cyprus 0 2 5 0 0 1 2 0
Czech Republic 0 0 0 0 0 0 0 0
Denmark 0 0 0 0 0 0 0 0
Estonia 0 1 1 0 0 0 0 0
Finland 0 0 1 0 0 0 0 0
France 0 40 19 0 0 12 11 0
Germany 31 65 42 0 27 37 40 0
Greece 0 49 44 0 0 16 22 0
Hungary 0 24 15 0 0 10 7 0
Ireland 0 10 21 0 0 7 13 0
Italy 0 196 159 55 0 65 77 19
Latvia 7 5 4 0 3 3 2 0
Lithuania 0 2 4 0 0 2 2 0
Luxembourg 0 0 0 0 0 0 0 0
Malta 0 2 2 0 0 0 1 0
Netherlands 42 30 16 0 17 7 8 0
Poland 127 104 80 0 46 33 40 0
Portugal 9 11 16 0 3 3 8 0
Romania 0 34 43 0 0 12 20 0
Slovakia 0 6 5 0 0 2 2 0
Slovenia 0 5 3 0 0 3 2 0
Spain 0 32 54 0 0 19 37 0
Sweden 0 0 0 0 0 0 0 0
United Kingdom 35 54 75 0 17 34 45 0
EU28 255 699 648 56 115 277 359 19
The extent to which the tonnages reported in Table 7-8 are expected to contribute to national MSW recycling rates in 2035 is presented in Table 7-9. It can be seen from the
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Table below that under the full implementation scenario a number of Member States would not have to achieve 50% recycling.115 This is because under the existing target countries are allowed to report against the MSW target using one of four calculation methods. Under the 70% scenario, only one method is assumed to be allowed (i.e. method 4) and this means that all Member States should achieve this recycling rate.
It is clear that under full implementation, where much larger volumes of material will be passing through MBT facilities, the recovery of materials for recycling can make a substantial contribution to the overall recycling targets. According to the data contained in the Municipal Waste Model, Poland’s MSW recycling target under the full implementation scenario will be bolstered by an estimated 6.6% in 2035. Greece comes in second with recovered materials from its MBT processes potentially adding 4.3% to its total MSW recycling rates. Greece is trailed closely by Malta (4.2%), then Croatia (3.9%), Cyprus (3.3%) and Latvia (3.0%).
Where municipal preparation for reuse / recycling rates are increased to 70% the contribution of MBT recovered materials diminishes markedly (Figure 7-3 and Table 7-9). The analysis conducted here suggests that for all countries, other than Poland, recycling from MBT will add less than 1% to the overall recycling target when MSW recycling rates climb to 70%. Eunomia’s analysis conducted using the European Reference Model on Municipal Waste Management suggests that Member States will have to collect between 76% and 79% of their MSW in order to account for the removal of non-target materials and other material losses along the supply chain. This effectively leaves even less material available for treatment by MBT facilities and helps to explain why the MBT recycling contribution is so low under the 70% preparation for reuse / recycling scenario.
115 Article 2(2) in Commission Decision 2011/753/EU Establishing Rules and Calculation Methods for Verifying Compliance with the Targets set in Article 11(2) of Directive 2008/98/EC of the European Parliament and of the Council, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32011D0753
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Figure 7-3: Material Recovery from MBT – Impact on Recycling Rates in 2035
The inclusion of ORO in Member States’ recycling targets would have a far more pronounced impact on overall recycling performance than that outlined above. Eunomia is aware that a number of Member States have developed (or are in the process of developing) end-of-waste standards which can be met by ORO. Such standards would allow far more material to be counted as having been recycled and is something that should be considered more closely by the Commission.
0.00%
1.00%
2.00%
3.00%
4.00%
5.00%
6.00%
7.00%
Czech RepublicDenmark
Sweden
Finland
Belgium
Luxembourg
Bulgaria
France
Germany
UnitedKingdom
Spain
Estonia
Austria
SlovakiaNetherlands
Lithuania
Slovenia
Ireland
Portugal
Hungary
Italy
Romania
Latvia
Cyprus
Croatia
Malta
Greece
Poland
Full Implementation Scenario 70% MSW Preparation for Reuse / Recycling Scenario
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Table 7-9: Contribution of MBT Recycling to MSW Recycling Targets for Two Scenarios
Member State
Full Implementation Scenario 70% MSW Preparation for Reuse / Recycling Scenario
Total MSW Recycled
MSW Recycling Rate
Contribution of Recycling from MBT Facilities
to MSW Recycling Rate
Recycling rate without
contribution from MBT
Total MSW Recycled
MSW Recycling Rate
Contribution of Recycling from MBT Facilities
to MSW Recycling Rate
Recycling rate without
contribution from MBT
a b c b - c a b c b - c
thousand tonnes
% thousand
tonnes %
Austria 3,272 55% 1.0% 53.6% 4,181 70% 0.4% 69.7%
Belgium 3,164 53% 0.1% 52.9% 4,142 70% 0.0% 70.0%
Bulgaria 1,572 50% 0.2% 50.0% 2,177 70% 0.1% 69.8%
Croatia 877 36% 3.9% 31.9% 1,697 70% 0.9% 69.2%
Cyprus 220 34% 3.3% 30.9% 448 70% 0.6% 69.4%
Czech Republic 1,972 31% 0.0% 30.6% 4,482 70% 0.0% 70.1%
Denmark 2,488 51% 0.0% 51.3% 3,375 70% 0.0% 70.0%
Estonia 219 36% 0.7% 35.2% 423 70% 0.2% 69.9%
Finland 1,611 50% 0.1% 49.9% 2,243 70% 0.0% 70.0%
France 15,286 39% 0.4% 38.3% 27,374 70% 0.1% 69.9%
Germany 29,923 61% 0.5% 60.5% 34,249 70% 0.3% 69.7%
Greece 2,169 34% 4.3% 29.9% 4,392 70% 0.9% 69.1%
Hungary 1,563 32% 2.5% 29.5% 3,393 70% 0.5% 69.5%
Ireland 1,958 50% 1.6% 48.0% 2,747 70% 0.7% 69.3%
Italy 16,560 40% 2.5% 38.0% 28,421 70% 0.6% 69.4%
Latvia 506 50% 3.0% 47.0% 705 70% 1.2% 68.8%
Lithuania 428 30% 1.5% 28.9% 980 70% 0.4% 69.6%
Luxembourg 283 55% 0.2% 54.3% 362 70% 0.1% 69.9%
Malta 86 29% 4.2% 25.2% 203 70% 0.6% 69.5%
Netherlands 6,595 55% 1.3% 53.8% 8,332 70% 0.4% 69.7%
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Member State
Full Implementation Scenario 70% MSW Preparation for Reuse / Recycling Scenario
Total MSW Recycled
MSW Recycling Rate
Contribution of Recycling from MBT Facilities
to MSW Recycling Rate
Recycling rate without
contribution from MBT
Total MSW Recycled
MSW Recycling Rate
Contribution of Recycling from MBT Facilities
to MSW Recycling Rate
Recycling rate without
contribution from MBT
a b c b - c a b c b - c
thousand tonnes
% thousand
tonnes %
Poland 4,687 33% 6.6% 26.7% 9,745 70% 1.2% 68.8%
Portugal 1,958 31% 1.9% 28.6% 4,528 70% 0.3% 69.6%
Romania 2,569 28% 3.0% 24.8% 6,573 70% 0.5% 69.4%
Slovakia 844 30% 1.3% 28.7% 1,959 70% 0.2% 69.8%
Slovenia 492 50% 1.6% 48.5% 682 70% 0.7% 69.4%
Spain 12,737 50% 0.7% 49.5% 17,709 70% 0.3% 69.7%
Sweden 3,372 56% 0.0% 56.2% 4,176 70% 0.0% 70.0%
United Kingdom 26,007 50% 0.6% 49.3% 36,142 70% 0.3% 69.7%
EU28 143,419 46% 1.2% 45.1% 215,842 70% 0.4% 69.6%
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8.0 Other Contractual Deliverables
The sub-sections below outline how Eunomia addressed the remaining tasks set out in the Terms of Reference for the project.
8.1 Additional Analysis and Technical Support
In addition to the technical analysis and research presented as part of this report, Eunomia provided the Commission with support in answering a number of questions raised during the course of the project. This additional technical support was provided on an ad hoc basis in the form of briefing documents which provided some additional insights on particular issues.
8.2 Dissemination of the Result
An official project website (www.thewastetargetsreview.eu) was set up at the start of the contract to provide details about the ongoing work under the targets review project. This website was maintained for the duration of the project and a screenshot of the home page is provided in Figure 8-1.
Figure 8-1: The Waste Targets Review Website
As part of the process of disseminating the Municipal Waste Model, Eunomia was also required to attend two country visits with the European Environment Agency (EEA) and the European Topic Centre on Waste Management and the Green Economy (ETC). Portugal and
127
the Czech Republic were the two countries selected by the EEA for this process and the country visits were undertaken in the autumn of 2015. Eunomia developed a spreadsheet pro-forma to assist the countries with capturing the necessary data ahead of the country visits and also contributed to the necessary preparatory work.
8.3 User Guidance and Technical Documentation
The Specification required that additional user guidance and technical documentation be developed. The time allocated to developing additional user guidance was used to expand on the guidance included within the Municipal Waste Model and on extending this to cover the newly incorporated Packaging Waste Model. The packaging element was added to the Model as part of this contract and this required that it be fully integrated into the user interface. An example of some of the user guidance is provided in Figure 8-2.
Figure 8-2: Example of Guidance on Packaging Waste in the EU Waste Model
The contract also required that additional technical documentation be provided to explain some additional elements of the Municipal Waste and Packaging Waste Models. Two additional technical annexes were produced and delivered to the EEA along with the final version of the Municipal Waste Model.
8.4 Training and Helpdesk Support
An important aspect of this project was providing training and technical support on the Municipal Waste Model through a ‘helpdesk’ function. The Terms of Reference for the project required that ten days be reserved for responding to questions and comments from the EEA and ETC in relation to the Municipal Waste Model. In addition to a number of technical questions, numerous comments on the model were also received. Many of the comments required that additional elements be added to the model which had not been
128
stipulated in the Terms of Reference. In order to allow for more time to be dedicated to assisting the EEA / ETC with questions posed through the helpdesk, time was reallocated from the training tasks to the helpdesk. A single training session was provided in Belgium in February 2016 and this covered a variety of topics identified by the EEA / ETC.
8.5 European Reference Model on Municipal Waste Management
As part of this contract Eunomia was responsible for delivering a final version of the Municipal Waste Model to the Commission / EEA. The final version of the model was handed over to the EEA in September 2015, with a number of updates being made since this time through the helpdesk function. Since September the EEA has hosted the ‘live’ version of the model which is now under its control.
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Appendices All appendices have been prepared as separate documents.
A.1.0 Analysis of New Policy Options
A.2.0 Country Summary Reports
A.3.0 Understanding Material Losses
A.4.0 Industry Quality Specifications for
Secondary Materials