This article is part of our special report Recycling of e-waste plastics.
Around half of e-waste plastics are not recycled in Europe but rather shipped abroad where they often end up being dumped or burnt. Simpler laws on recycling in Europe would help keep those materials at home and recycle them, argues Chris Slijkhuis.
Chris Slijkhuis is General Manager of MGG Polymers and board member of the European Electronics Recyclers Association.
A recent report has shown that around half of WEEE plastics, are not entering proper recycling channels. So where are they going?
Until only a few years ago, most of these plastics disappeared from Europe. The majority went to China. At some stage, China realised that they were also importing environmental problems. On 1 January 2018, China banned the import of these plastics from Europe or from anywhere.
Many of these Chinese recyclers – and there were many of them – went to other places in the Far East. They went to Vietnam, and then Vietnam closed their doors, and they went to Malaysia, India, England and Serbia. In the past, I would think that something like one million tonnes of plastics went abroad. This is largely reduced by the China ban, but there are still exports.
What is the issue with WEEE plastics going to those countries?
Half of the material coming from electronics waste is not recyclable. The problem with these non-recyclable plastics is they can also have restricted additives, which the legislators do not want anymore.
Now either, these recyclers use the plastics with the additives, which is not good, or they separate them. The good ones do that.
The majority of these Chinese recyclers, now also in Malaysia and in Vietnam, are tropical places, so they don’t have incinerators for recovering the heat and the energy from the plastics. What often happens is that, at best, they will be landfilled, but in smaller locations, you can imagine what has happened.
How can the industry and the European Commission work together to prevent WEEE plastics leaving Europe?
It’s going to be much more difficult. The Basel Convention two years ago took a decision, which I call the Norwegian proposal, which said in order to reduce marine litter, you have to make it more difficult for plastics to be transported anywhere.
They made a ruling that only pure plastics that have been recycled can cross borders, without any prior consent, without any controls. Every mixed plastic needs to be notified.
The report also says that only 2% of WEEE plastics containing brominated flame retardant is currently recycled – how can that be improved? Can WEEE plastics ever become circular?
WEEE plastics are circular already for a good proportion. If you take the whole cake of these plastics, shown in the report, only between 7-10% contain brominated flame retardants. That means that 90-93% is a material that does not have flame retardants.
The problems with the flame retardants is that a proportion are restricted substances. They cannot re-enter the circular economy. But we as a recycler cannot make the distinction between flame retardant Y and flame retardant Z. Y is prohibited and Z is permitted.
So there will always be a certain amount of waste in this system?
There’s always going to be a certain amount of waste. Many of these plastics are what I call ‘exotic plastics’. There are four types of plastics that are mainly used, but there is a whole lot of exotics, which are present in far too small percentages to be recycled.
How do you prevent the issues with some brominated flame retardants returning in children’s toys or food packaging?
This is one of the things that you often find in NGO reports. Toys are mainly produced in China. There is hardly any toy production in Europe and we, as European recyclers, at least in the company I am managing, have a very clear policy: recycled plastics cannot be used in toys and cannot be used for food contact.
There is also product legislation in Europe that prevents this. So, if there are flame retardants in plastics found in toys, you may safely assume that this material doesn’t come from Europe.
Turning to the threshold, which the report recommends is raised from 2000 to 6000 ppm. The European Environment Bureau has called that “ludicrous” saying brominated flame retardants should be phased out completely – what is your response to that?
Let’s face it, some electronic equipment creates heat. Plastic is a solidified oil. That can burn. For product safety, there is some legal requirement to add flame retardants.
The amount of restricted brominated flame retardants is continuously reducing, as they were restricted long ago. So when the EEB and NGOs say “all of brominated flame retardants are bad”, this is a mistake. We need to have flame retardants. There are a number of brominated flame retardants that can absolutely be used without any problem – they’re not restricted, they have no issues.
In 2014, when we did this first standard with 2000 ppm of bromine, we were absolutely certain that you we would not hit the threshold levels set by law for the restricted flame retardants. As the level of restricted flame retardants goes down in the waste, you can imagine that you’re still safe if you increase the bromine levels.
The mistake that EEB and some non-toxic NGOs are making is that they simply call all brominated flame retardants “hazardous stuff”, which is not correct. Let’s face it, bromine is a normal element in nature, you will find huge quantities in the sea for instance, and we need tiny amounts of it even in in our food.
We fear that alternatives to brominated flame retardants might turn out to become regrettable substitutions, as any separations techniques still fail and as these might result in degradation of the recycled materials eventually.
You previously raised the issue of lawmakers constantly changing regulations and making it hard to invest in recycling – how can there be one policy which is safe, but easier for recyclers?
It would be easy if we just had one chemicals legislation. I hoped when REACH was introduced in 2007 that we would indeed have one piece of legislation that regulates all substances.
We have a number of legislations all ruling the same substance. The same substance is discussed in REACH, but it’s also discussed in RoHS and in the POP regulation. At the same time, it’s discussed in the Basel Convention and in the Stockholm Convention on a global level.
What happened in 2017 is that, suddenly, the European Union had to implement the decision of the Stockholm Convention that deca-PBDE was a persistent organic pollutant, and the European Union had to set a threshold level for it. The Parliament – they take decisions on emotions, and not necessarily on facts – took the decision that it’s bad, we need to reduce it, let’s make it 10 ppm.
That 10 ppm means we cannot recycle anymore, because we cannot check this, there is no measurement system for it. You can send it to an external laboratory to do a very expensive analysis on it. But we as a recycler in our day-to-day operations, we cannot send every sample to an external laboratory, do an analysis of €1000 and then come back with the results.
We need to have something simpler. And this simpler method is what we call the XRF measurement system. This XRF measures only an element, in this case only bromine. This bromine measurement system is only validated for 1000 ppm. You can have lower readings, but the measurement is not validated, so it’s not necessarily what the reading says.
The European Commission wants a circular economy for plastics. How can recyclers do that?
Let’s take persistent organic pollutants regulation in Europe. The POP regulation was implemented and published in June 2019. What I find surreal is that even one year after this there was a big discussion in the Basel Convention. The Basel Convention came to the conclusion, ‘We have to discuss this again and, at the next Conference of Parties, we want to see if further reductions of these levels can be done.’
Well, this is an obligation for the European Union, so the European Union came back and set a new consultant at work to see what further reductions can be made. We are confronted, again, with the new discussion around the threshold levels of the same set of substances.
Of course, this makes people who want to invest in this industry very unhappy and uncertain. They don’t want to invest in an industry where even within the permitting time of the factory, you can come into a situation that you made the investment and now the investment can be stopped because we cannot do it anymore.
You mentioned the Norwegian proposals earlier, coming into force in 2021 – what is the impact of those on WEEE recycling?
On January 1 2021, the delegated act will be implemented, in which only clean plastics that will not create any further waste can be moved without any problem. Everything else needs to have a notification. There is a third category that is not only mixed, but also mixed and contaminated plastics, which are then called hazardous waste, which needs to have a notification as well.
The problem with a classification as hazardous material is that most recyclers of WEEE plastics in Europe, do not have a permit to take in hazardous waste. The delegated act, as it is now, doesn’t really make a statement on whether plastics with brominated flame retardants are considered hazardous material.
What we, as an industry asked for, is WEEE plastics, always containing some brominated flame retardants, requiring a notification anyway, can be transported as mixed plastics.