Policy expectations from the industry
Main takeaways
- Legislations related to EPR schemes, substances of high concern and green public procurement are expected for the coming years and aim to improve the traceability, standardization and stability of recycled materials.
Further readings (optional)
If you're interested in legislation and the European plans towards a CE: The WEEE Directive, The Ecodesign Directive, The European Green Deal, The Circular Plastics Alliances
Expert 1:
For the recycling of plastics, I expect more developments on the organization of the EPR
schemes, so the extended producer responsibility schemes. There are a lot of experiments
going on at the moment or other sectors are also looking at EPR schemes, introducing them.
I can imagine that learnings from all kind of these schemes are being collected more and more.
And we're trying to improve those schemes and one of the things which is already going on in
for example the packaging schemes is that there are differentiated tariffs for the packaging
that are easy to recycle. And we’re looking also at differentiated tariffs for packaging made
with recycled plastics for example. And I can imagine that this will also become part of the
EPR scheme for electronics.
I can expect that there will be an increased policy about substances of very high concern and
legacy chemicals that are inside some of the plastics. And recyclers need to do something with
that in there as it will have an effect on their process. I can imagine they will need to prove
the origin of where their recycled plastics are coming from and that can be done maybe with
blockchain or markers for example. So that is a technological development coming from a
policy development. I think that is one of the probable developments of policy that will have
an effect on the recycling process
I think another development could be of course green public procurement, with the
governments. We already see that for a couple of years in the United States where they have
the EPEAT which is also green public procurement certification where they have mandatory
percentage of recycled plastics for example printers and other equipment governments are
using. This has a big effect on the use of recycled plastic so possibly more of that is coming in
the next years and it’s expected.
Expert 2:
What is happening at this right very moment is that from this sector, the recycling sector, we
are setting up certain analysis technologies and then it is mainly one of the biggest problems
that we have is REACH, that’s chemical legislation in Europe. It is very extensive.
If you’re a producer of a virgin material you know what you put in, so you know what you have
to analyze on. If you’re in recycling, you put in everything and if you know the REACH, the
substances of very high concern and the POP substances and so on. you add up all those
substances, you have over 600 chemical substances now. I don’t have to tell you that it is
economically not interesting to analyze all 600 of them on every lot. So, we have to come to
a kind of screening method that will be standardized.
As a sector we are working on that screening method, next step is standardizing that and then
we can go to policymakers and say now please here we have a good method that is working
please enforce this.
To make the comparison with the PET bottles for instance, when did Europe require a 30%
recycled content in PET bottles was only after industry had shown that it was possible so this
also in electronics I believe that first as an industry we have to show that it is possible and
then in the end Europe will make it mandatory. So, in my view it really has to come from us
and from producers of course they still have to use it and that's going to be a joint effort for
the coming years.
Challenges in Recycling legislation : Shifting the focus from quantity to quality
Main takeaways
- The downside of requirements for recycled content and mixed plastics is that producers and sorters focus on achieving targets in the most cost-efficient way which may hamper further innovation of the recycling process.
- The industry needs incentives to improve the recyclability of products and the recycling process. This can be stimulated with quality standards for recycled plastics
Expert 1:
The European Commission is already busy with the policy regarding mandatory percentages
of recycled plastics for certain product categories. The electronic sector is not mentioned yet
but I can imagine that this also in the short-term this will be one of the sectors with the
mandatory percentage of recycled plastic for certain product categories, not for all yet. But
probably first the more easy categories without food contact or skin contact.
People are always optimizing towards the policy and this can have also sort of rebound effect
so in packaging for example there are agreements that sorters can sort for example a
maximum of 45% mixed plastics. And well, this is then what they are aiming for instead of
decreasing the mixed plastics and improving the mono streams. They are aiming for a
maximum of 45%, which is then most cost efficient and is not about the quality but more
about the volume and the cost efficiency of that. So, usually there are disadvantages like that
in all kinds of EPR schemes and you need have other incentives to try to come over those
barriers.
Expert 2:
We have some improvement to make in the collection but the policy should concentrate on
how the material that is collected is also treated is it also treated in in qualitative good way
that brings out highly qualitative secondary raw materials. This is the policy future I would
expect. Today we are in between collection rate, then we focus in the policy on the so-called
depollution, get out hazardous substances out of the waste stream. And in the future, I hope
that the grade on how you measure the efficiency of a recycling process will be how many
highly qualitative raw materials you bring out and bring back into our circle.
We are at the moment it's the case that we have to individually negotiate with each
compounder with each supplier the quality of the recycled plastics we are using. And this is a
hard job because you go into individual discussions with each possible supplier and it
sometimes went out that nobody can deliver the quality and then you start the process from
the beginning that's why we are at the moment counting on the standardization stream of the
so-called Circular Plastic Alliance. We already defined commonly accepted quality grades for
recycled plastics. For example, alongside with the CPA (Circular Plastic Alliance) we now
started at the NEN, at the Netherlands standard organization, the project for quality grades
of recycled PP and these are important instruments, these quality standards that exist for long
time for example for steel for copper and for other important elements to get the market for
recycled plastics running.
Incentives rather than obligations I think would be great. In the cases where we have seen
requirements on using recycled materials, if the price then goes up for the recycled materials,
suddenly we will see an inflow of a lot of materials with recycled claims, which in reality are
virgin. Because the material that is called recycled is more expensive than virgin. Suddenly
there are some actors in the market happily branding their virgin material as recycled and the
market is not improving really.
If you have specific requirements on the use of recycled, let’s say that plastics parts need to
contain 20% recycled plastics. Currently that is very hard to verify on that component, it’s not
really easy to see which molecules are recycled and which are not
Challenges in Recycling legislation: Regrettable substitutions
Main takeaways
- The restrictions for the use of chemical substances in products leads to challenges for the recycling of products that were produced before those legislations existed.
- Recyclers expect an ongoing change in regulations, for instance for flame retardants. This will lead to a future challenge if there are no technologies in place to identify and separate these substances in the recycling process.
- Designers can contribute to solving this problem by designing products in a way that plastics containing any flame retardant are easy to separate from the rest of the plastics in a mechanical or chemical recycling process.
What I expect most from recyclers’ side what we ask from investors’ side also is stability in
legislation and that is probably the main barriers today why there is not so much recycling
capacity in Europe, it is because the legislation, chemical legislation changes all the time
For the future what we are facing is the forbidden molecules, for the parts with high concern
substances. Because, we are, the recyclers are victims of the past, which means that the
authorities gave license to produce toxic substances and now we are facing a lot of problems
to separate those very complicated molecules, those additives that they put in the plastics.
One of the biggest issues if you look back in the past is that we see one flame retardant being
restricted, it's being replaced by another one but chemically similar so 5 to 10 years later also
that one is being restricted and would come with a replacement and so on and so on, so it’s
kind of a never-ending story of replacements that are being restricted. And in the sector, we
start talking about regrettable substitution. And that is really, that is one thing what I'm really
afraid of what you see today is that there is an evolution towards on the one hand polymeric
flame retardants, because it is bound to the polymer, that it is less likely to degrade into a
toxic compound. But a polymeric flame retardant, for instance cannot be removed by
dissolution so if by any chance that polymeric flame retardant would become restricted in 10-
15 years, then dissolution will not work anymore. That is one. The second evolution that we
see is towards phosphate-based flame retardants and that's an evolution that is already going
on for quite a while. There is a big difference in recycling a brominated flame retardant
because bromine is a heavy element it makes the plastic more heavy and we can quite simply
separate them by density separation. A phosphate-based flame retardant, phosphate,
phosphors is not as heavy as bromine so the density difference is less important than with a
brominated flame retardant which as a consequence has that for us it is technically practically
impossible to make a separation between the non-flame retardant plastic and the phosphate
based flame retardant.
Should that happen that is phosphate-based retardant become restricted and it is already the
case for two of them, then we might face a huge technological issue because today there is
no technology available and there is no technology under development which will be able to
do that separation.
To summarize this in a design for recycling mindset, how can you solve this? If you start
designing a plastic and you design a plastic with a flame retardant, well then design it so that
the density of that plastic is significantly different from a non-flame retardant plastic. So that
means that with current technology it will always be possible to separate them, whatever
happens. And set aside of being restricted or non-restricted there is also another aspect. And
then looking more towards design from recycling. If you want to source a recycled plastic for
use in whatever application, it is the same as with a virgin plastic today you want to know
exactly what is in. So as a producer, the producer will never be happy with a recycled plastic
where the recycler says, there is some flame retardant in there, phosphate based, it is not
restricted, but I don’t know how much. And that is not acceptable either. So also, from that
aspect it would be good to design a flame retardant plastic so that it can always be separated
from on a non-flame retardant plastic, choices they (designers) make they immediately impact
the recycling in 5 to 10 years.