ZWE warns of unaddressed human and environmental health hazards in EU recycling proposals

28 Feb 2023 --- Zero Waste Europe (ZWE) is criticizing the newly released study by the European Commission (EC) about plastic recycling as it does not sufficiently address human health risks and environmental aspects.

Recycling is an important strategy in the circular economy. However, definitions of quality in recycling are scarce and a widely supported framework to measure the quality of recycling has yet to be established in an industrial or policy-making context. In the EC study, an operational framework is theoretically described and demonstrated in a case study on PET. 

“The suggested framework moves in the right direction by adding environmental impact and introducing a long-term vision to the substitution potential of recycled material, thus allowing for putting closer the climate, environmental and circular economy agenda,” Lauriane Veillard, policy officer on chemical recycling and plastic-to-fuel, at ZWE tells PackagingInsights.

“However, this definition could go further when addressing the risk to human health arising from the presence of hazardous substances, taking into consideration the environmental aspect of the definition more globally.”

“Indeed, a recent study found that only PET food-grade plastic is available in Europe, but even that has toxicity risks and there is no food-grade recycled plastic made from olefins (HDPE, LDPE, PP) or polystyrene because of uncontrollable toxic chemicals created in the recycled plastic,” highlights Veillard. 

EC report findings 
The objective of the EC study Towards a better definition and calculation of recycling is to make a technical proposal for revising the implementing decisions related to recycling given the expected development of new and advanced multi-output recycling technologies, such as chemical recycling technologies that are reportedly likely to emerge in the coming years.

The main findings of this report can be summarized as:

• A compilation of calculation rules for estimating the recycling yield for multi-output technologies based on a mass balance approach.
• A clarification on calculation rules for estimating the recycling yield of biodegradable waste (including both bio-waste and compostable plastic waste).
• The estimation of preliminary costs and environmental burdens and benefits that may arise from implementing calculations rules and changes proposed herein.
• The proposal of a new framework for defining quality of recycling with its application to a case study.

ZWE says the EC recycling definition must address the risk to human health arising from the presence of hazardous substances.One of the main pillars of the European Green Deal is the new Circular Economy Action Plan adopted by the EC in 2020. Key importance is given to achieving the EU’s 2050 climate neutrality target, announcing sustainable initiatives along the entire life cycle of products and promoting a circular economy and ensuring that waste is prevented and the resources used are kept in the economy for as long as possible.

Challenges to industry compliance
Veillard explains the main challenge for the industry to comply with the EC framework would be access to high-quality recycled content, as there is an increasing interest in second raw materials following recycled content targets introduced in the EU legislation. 

“Indeed, in the case of PET, for example, there is competition between food-contact packaging and textile to access high-quality PET. In our report ‘How circular is PET?’ we found that approximately 14% of the global polyester market is recycled polyester, the majority of which is produced from PET bottles.”

“As it is not possible to have food-contact materials from polyester textile, the food-contact materials industry should have ‘priority access,’ or a similar mechanism that guarantees a ‘right of first refusal’ to beverage producers to facilitate their fair access to the food-grade recycled materials coming from the products they placed on the market and which were successfully collected,” she continues. 

Recycling framework
The EC framework builds upon three dimensions. The first dimension is the Total Substitution Potential (TSP), which indicates to which extent a secondary material can provide the same function as the primary material. 

The TSP value depends on the Technical Suitability for Substitution, the Market weight, which represents the market share of a given application in the market of the corresponding material, the End-Of-Life Recycling Rate and the Economic Boundary Conditions. 

The second dimension is the Long-Term in-Use Occupation, which indicates how much of a certain material is still “in use or functional” in society over a certain time horizon. The third and last dimension is the Environmental Impact, which can be measured by common LCA approaches. 

Each of the three dimensions defined in the presented framework can be evaluated mathematically, which offers a quantitative way to assess the quality of recycling and compare different recycling techniques, different applications and geographical difference in waste management practices.

ZWE’s policy officer on chemical recycling and plastic-to-fuel Veillard explains the main challenge for the industry to comply with the framework is accessing high-quality recycled content. PET bottle recycling 
The framework is applied to the case of recycling of PET. The results indicated that closed-loop mechanical recycling of PET bottles has the highest quality of recycling, whereas the chemical recycling of PET fibers has the lowest quality of recycling.

Making a framework for assessing the quality of recycling operational is an important step forward for industry, policy makers and researchers to steer development in waste management processes. 

This section presents an operational framework, integrating many aspects of quality allowing integrating over the different dimensions. This allows assessing the recycling pathways that are less interesting from a quality perspective or the pathways that should be included in future recycling advances. 

Although the EC says it recognizes that its framework requires further elaboration, the presented work is said to offer a solid frame for discussions across different material types. It can therefore be of great value in moving forward in the transition to a more circular economy for materials and resources.

Designed to recycle
The EC emphasizes that it has so far not taken any steps for the revision of the definition of recycling. Therefore, the present document contains technical proposals and does not constitute the official opinion of the EC regarding the revision of the definition of recycling and related calculation rules.

Furthermore, the EC document does not constitute any commitment by the EC to start work on the revision of the definition of recycling and related calculation rules.

Veillard stresses that the quality of recycling depends on the type of input and its quality. 

“In the context of the Packaging Waste Regulation (PPWR), strong incentives should be developed at the manufacturing stage to ensure that products are really designed for recycling, by lowering the number of additives and moving toward mono materials.”

“Studies say that around 80% of the greenhouse gas emissions during the treatment of waste could be avoided with a real design for recycling,” she concludes.

By Natalie Schwertheim