Waste Not, Want Not

Editors’ Note: The following text is an edited excerpt of a transcript of David Barrio’s presentation from Paper Recycling Conference – Europe, which was Nov. 8-9, 2011, in Barcelona, Spain. The European Commission is expected to approve end-of-waste criteria for paper, glass and copper during a May 4, 2012, meeting of its Technical Adaptation Committee.

When I received the invitation to come and make this presentation this summer, I thought that by the time of this presentation we would have a clear framework, a clear regulation, or at least that we would be in the final steps of this process. Unfortunately, this is not the case, and we still have the draft that was issued in May 2011.

Background
For those of you not too familiar with this End-of-Waste thing, in the Waste Framework Directive (WFD) (2008/98/EC) there was a new procedure for defining End-of-Waste criteria, which are criteria that are given to certain waste streams in order to cease to be waste. That means certain waste will not be waste once “something” happens. This “something” that happens is what we are working on.

Waste streams that are candidates for end of waste must have undergone a recovery operation and comply with a set of specific criteria. These criteria have to be defined for each specific waste stream, but the general conditions that a waste material has to follow are defined by Article 6 of the WFD in the following terms:

a. The substance or object is commonly used for a specific purpose, which is very clear for paper;

b. A market or demand exists for such a substance or object;

c. The use is lawful (technical requirements and standards apply); and

d. The use of the substance or object will not lead to overall adverse environmental or human health impacts.
 

It is very clear that paper and board is one of the best candidates, and that was the case when the paper industry went to the commission and said, “We want to be the first material to be in this process.” So, the industry is asking for that.

The IPTS/JRC (Institute for Prospective Technological Studies/European Commission Joint Research Centre) here in Seville, Spain, I think has done a wonderful job of setting up background studies to establish the criteria. There was representation from all the stakeholders—ERPA (European Recovered Paper Association), FEAD (European Federation of Waste Management and Environmental Services), CEPI (Confederation of European Paper Industries), all the member states and different interested parties that formed a technical working group. This group resulted in technical documents that were sent to the commission to prepare the regulation. The work by IPTS has been finished for a year or so and now it is in the hands of the commission to issue a European regulation. This means that a European regulation will be enforceable the day after the publication or whenever the period of implementation is set in that specific regulation so it doesn’t need any transposition. It will be applied directly into the legislation of the different countries and then it will enter into force, though it has to be scrutinized by parliament and council in Brussels.

The IPTS technical report was delivered in July 2010 and the draft regulation was issued in May 2011. As I said, I thought that by the time that I was here today we would have some final regulation or at least a more advanced draft that we could discuss, but this is not the case, and this first draft regulation is still the only thing that we have to discuss.

Criteria
Product Quality. According to the end-of-waste principle, waste ceases to be waste when a useful and safe product is placed on the market. The whole issue is about quality.

The target of the commission is to improve the quality of recycling in general. The quality of recycling depends on the quality of the materials that are going to be recycled.

The four framework conditions that I mentioned before are:

a. Commonly used;

b. A market or demand exists;

c. Meets technical requirements, legislation and standards; and

d. No overall adverse environmental or human health impacts.

Then there is a set of specific criteria that has to be designed for every different material. Scrap metals and aluminum already have their regulations on the market, and now it is our turn for paper, and some other materials are in the process of being studied. But obviously this criteria is specific to the different materials, so each material has different criteria that have to be applied: Criteria about input materials; what quality control measures are required to fulfill the product quality targets; what is the provision of information that must accompany the load or consignment; and what are the processes and techniques that are permitted and forbidden.

These draft regulations that we still have on the table and that have not been changed since May 2011 have this criterion: “Recovered paper must be graded according to EN 643.” (EN 643 is the European specification for standard grades of recovered paper and board.)

That is why meeting the standard is so important. In order to be something that is considered a product and not waste, it has to be graded according to the standard EN 643.

The other very important issue is that the draft sets a limit for nonpaper components of 1.5 percent, and that is defined as the material that can be separated in a dry sorting process. That is something that can be taken by hand or by automated devices but in a dry sorting process. That means, for instance, that adhesive paper on corrugated boxes would not count because it is not feasible to do so. That 1.5 percent is only for the material that can be sorted in a dry sorting process. That is something that was not included in EN 643. In the current EN 643, the limit is zero. In principle, all the grades in EN 643 will be outside the scope, so that is why we are in the pilot process of a revision of EN 643.

Additionally, from what we have heard the European Commission is now planning to include another tolerance of 0.5 percent for those nonpaper components that cannot be separated in a dry sorting process, such as acetate or a staple in a newspaper. There is an exception for multi-layer packaging (e.g., beverage cartons, frozen food packaging), which are counted as nonpaper components. It is not that a piece of frozen food packaging is not allowed, for instance, in a bale of 1.04 (the ERPA specification for supermarket corrugated and board). It means that if you make a bale of only frozen food packaging, that will exceed obviously the 1.5 percent, and it is not included in this legislation, though it cannot be separated in a dry sorting process. This is an issue that is being discussed now in the Commission and being pushed by the different secretarial organizations to try to find a solution for this specific type of product.

Regarding quality control, recovered paper suppliers will have to operate a quality control system at the point where the material ceases to be waste and becomes to become a product. That means if this waste is going to become a product in a recovered paper plant, before or at the time it is loading into a truck to a destination paper mill, it needs to go through a quality control system so that it can certify that it fulfills the legislation. That is a very new approach for the paper industry or for the paper loop as such because the supplier needs to make the quality control to fulfill the legislation.

Input Materials. Some input materials are obviously not permitted, such as hazardous waste, biowaste, mixed municipal waste, health care waste and used personal hygiene products, which is very much in line with EN 643. That is quite logical, and we all want to try to avoid these products in our recovered material.

Processes & Techniques. That was a very hard discussion in the IPTS/JRC because there was the issue of separate collection and commingled collection. The final agreement was that the problem is not where the paper comes from or the collection technique used; the real importance is the quality of that material. End-of-Waste legislation does not exclude paper originating from commingled household collection, but it has to fulfill the quality standards. In the opinion of most of us, I think it is quite obvious that a lot of improvements in sorting techniques and sorting technology and also in the way that commingled material is collected has to be put in place if we really want to fulfill this new legislation. Otherwise, that 1.5 percent would be very difficult to fulfill, and all of these prohibited materials, especially biowaste and mixed municipal waste, would be very difficult to avoid in these new materials.

Provision of Information. I said before we need quality control in the place that the material ceases to be waste, but that has to go with a document that says so. Recovered paper suppliers will sign a statement of conformity for every consignment—that is something yet to be defined—with the end-of-waste criteria. This has to be transmitted to the next holder. That means that somebody has to sign and certify that this is according to the legislation—according to the prohibited materials, processes, quality.
 

Hierarchy
One of the peculiarities of paper and board material that doesn’t happen with scrap aluminum, for instance, is that it can be burnt. For paper recyclers it was important to make sure that when waste becomes a product that it could not escape from the waste hierarchy, or escape recycling and go to incineration. End-of-waste paper is only to be applied to paper recycling and not to other uses for that material, such as incineration, pet beds and insulation.
 

David Barrio is recycling director of the Spanish Association of Pulp and Paper Manufacturers (ASPAPEL).