PVC boss: ‘We will not change our reputation in one day’

Brigitte Dero, General Manager of VinylPlus. [VinylPlus]

This article is part of our special report Transition to green economy.

IKEA’s decision in the 1990s to ban PVC from its furniture and textile products had a devastating impact on the industry’s reputation. But 15 years after phasing out the most toxic chemicals, the PVC sector believes it is now ready to gain acceptance as a sustainable material, says Brigitte Dero.

Brigitte Dero is General Manager of VinylPlus, the voluntary sustainable development programme of the European PVC industry.

Dero spoke to EURACTIV’s publisher and editor, Frédéric Simon, ahead of the T2gE conference in Bratislava.

Improving recycling rates is a key objective for the EU’s circular economy package but a lack of incentives often hampers reaching this objective. What financial incentives work best in your view?

As far as I know, there is no existing incentive in place to boost recycling, to support small and medium-sized companies who invest in recycling plants and develop that sector. I am speaking about recycling generally, not just PVC.

Knowing how much we as the PVC industry have invested in recycling, I really believe this would help. Financial instruments could help recycling plants, improve collection schemes, invest in better recycling technologies and improve the traceability of waste.

An idea that has been raised recently is for recycled materials to be exempt from VAT for example. Do you support this?

I have not heard about this but I can fully support it.

Why do you think this is not already happening?

Because I do not believe that we value waste highly enough as a resource. There is a lot of valuable waste, and some of it is recycled in Europe, but not enough. There is much room for improvement, and progress could create a pull effect that would encourage companies to invest more in recycling.

The European Commission has taken an approach based on setting targets, for example to recycle a certain percentage from municipal waste. Do you see this more as an incentive or a punishment?

Speaking specifically for the PVC industry, targets can be extremely positive. VinylPlus has its own ambitious target of recycling 800,000 tonnes by 2020, which is enormous. Today we are already recycling 500,000 tonnes, up from virtually nothing in 2000.

Targets are important because they give us an objective to reach for.

Did you set this objective because regulators told you or were pushing for it?

We set this target ourselves because we realised we had to manage the waste issue that PVC raises. In the late 90s we had large amounts of PVC waste going into landfill, and we knew this kind of waste was valuable so we started recycling it.

But waste is managed by public authorities, not industry. You could have just decided to ignore it.

Yes but we in the PVC industry believe in behaving responsibly: managing the end of life of our products is important.

But it has a cost…

Indeed, we have invested quite a lot. When we started in 2000 we had to pay private incentives to equip the European industry to take back and recycle our PVC waste. So in the last 15 years, more or less, we have invested €100 million to develop recycling activity.

Have you recouped that investment by using recycled materials? Is it cheaper to collect and recycle than to produce from new materials?

We will never recover this investment. But we believe it does have a value, and we are very proud of what we have done because it demonstrates that PVC can be 100% recycled. It is such a durable material that it can be recycled several times without destroying the molecules – the properties remain the same.

So in the long term it is a durable thing to do, because we are increasing the value of the recycled material and the quality of this material is good. It can be used in a number of applications that do not necessarily need virgin PVC.

So from a business perspective, recycling really makes sense for the whole PVC value chain.

The Commission is preparing a “strategy on plastics” to improve recyclability and biodegradability, among other objectives. What can be the contribution of the vinyl industry to both these objectives?

The plastics strategy has not yet been issued, but we know that plastics are one of the priorities of the circular economy package.

And there are a number of things we have identified as critical. One is the question of support for recycling. If you look at the current legislation, you have REACH on one side and the Waste Framework Directive on the other side. The link between waste and chemicals legislation is very strong.

In other words, waste is considered as a mixture of chemicals. As soon as any product containing a legacy hazardous substance becomes waste, it has to go through the REACH authorisation process, and is then automatically considered as hazardous.

And this is the case even if the product has always been perfectly safe: it is not understandable that products with which consumers have been in contact for many years without reported harm are suddenly considered hazardous at the moment they become waste. Recycling hazardous waste is much more complicated; it is a burden for recyclers and generates a lot of extra cost.

So would you say REACH hampers recycling?

It is the interaction between the two pieces of legislation that hampers recycling, and the lack of consideration for secondary raw materials. These are materials which, although they contain hazardous chemicals, can be categorised as valuable materials that can be re-used after proper analysis on a case-by-case basis.

That is something we would like the Commission to look at. We need to accommodate these materials in order to maximise recycling in a responsible way, rather than automatically classifying them as hazardous waste.

This classification makes it more difficult to process these recycled materials and find a market for them afterwards.

How would you solve this issue? You can probably understand the desire to prevent, as much as possible, hazardous materials finding their way back into new products via recycling.

We all want to achieve a toxic-free environment. This is why in the PVC industry we completely substituted lead in PVC in 2015 and in 2001 we completely substituted cadmium. So we are really keen to get rid of hazardous chemicals in PVC.

But what do you do about the lead or cadmium that finds its way back into products via recycling? Is there a maximum amount that can be tolerated?

With cadmium it was solved with a case-by-case approach. There are a number of applications for which we are allowed to use recycled PVC containing a certain amount of cadmium.

But when we talk about hazardous chemicals, it should be put in perspective.  Chemical additives in PVC are embedded in the polymer matrix of the material. That is why, despite our best efforts, we have been unable to remove these chemicals. They cannot be dissociated from the material. Extracting these molecules is simply not economic on an industrial scale.

When recycled PVC containing legacy materials is used in a new application, it can be sealed behind a layer of virgin PVC so these hazardous substances cannot leak out. In window frames for example, virgin PVC is used to give a white finish with UV resistance, and any recycled PVC is only used internally.

So you’re saying the PVC industry should be allowed to continue using these legacy materials, even though they may contain hazardous substances, as long as there are appropriate quality standards and safeguards?

Absolutely. With full risk assessment and on a case-by-case basis, depending on the application.

Can you give an example of an application in which this should not be allowed?

When we recycle the PVC from flexible products like hose-pipes, we use the PVC mainly in things like traffic cones or other road equipment. So this does not present a risk.

But in any case, in all applications for recycled PVC containing legacy chemicals, we carry out risk assessments to demonstrate that there is no risk. And this is also done for virgin materials in their first application. So the safety and quality of recycled PVC is of paramount importance to us.

But can you mention an example where recycling would not be acceptable or where it would present too many risks?

It is not always a question of risk. There are also applications we believe it does not make sense to recycle, so not all PVC can go through this process. For example, when PVC is mixed with other plastics, separating and cleaning the materials is too difficult, so it does not make economic sense.

So, as we confirmed in our commitment review in 2015, our preferred solution in such cases is energy recovery through incineration rather than landfill.

A recommendation we can provide as an input to the circular economy package and the Commission’s plastics strategy is that we would like to see a landfill ban on recyclable materials. We would also like to see more value placed on materials with a low carbon footprint over their full life-cycle. This is also important for the circular economy concept, for plastics in particular.

And also to develop the category of secondary raw material, with clear criteria to give certainty to the industry and investors to boost recycling.

Environmentalists are opposed to hazardous chemicals re-entering consumer products via the back door in the form of recycled products. ClientEarth called for an outright ban on the practice. What is your view?

You are probably referring to the case of DEHP, which is the first substance to go through REACH authorisation. A very small number of recyclers have applied for authorisation to use recycled materials containing DEHP in a very limited number of applications. They have followed the process in place: through ECHA and consultation with member states, the input of the Commission and so on.

So they have provided all the information they have been asked to provide. Then the decision was made to grant them an authorisation for a limited number of years, and they will have to provide all the details necessary to monitor the management of these recycled materials. So on the industry side, they have followed the process in place, and I cannot say more on that.

As the first case of an authorisation passing through the REACH process, of course this has attracted the attention of stakeholders, because it is a case study as well. I guess the member states did their homework .There was a very long consultation period, the Commission did its work as well, and in the end the decision was taken.

In its circular economy package, the Commission announced it will launch work to develop quality standards for secondary raw materials – in particular for plastics. What criteria do you think should apply?

The main principle, in our view, is to ensure the proper traceability of waste. We need traceability and certification to ensure quality, and also to secure investment in recycling in order to have the best technology in place. This will allow us to control what is coming into the plant and what is going out, and to know the content of the materials and which applications they will be useful for.

We already have a traceability system in place and we are pleased that the Commission has held us up as a good example on that, because we have already made 15 years of investment here and we have a good deal of experience. We call our system Recovinyl and it could even be improved, and used by recyclers of other plastics and other materials.

Improving traceability will help us to understand the composition of the waste, and eventually to create a huge database on the composition and applications of recycled and reused materials. We are thinking about using digital barcodes in order to automatise the tracing of the waste materials that we use, from collection to treatment and recycling.

This is something we have in the pipeline, and we hope that we can continue to work with the Commission and other authorities on further developing these ideas. But it all depends on how the circular economy concept is developed in the future. It covers both safety and quality.

And it has taken 15 years to get to this stage?

Yes, 15 years and a €100 million investment.

Earlier you mentioned energy recovery. Incineration is considered the least favoured option in the EU’s waste hierarchy. Incinerating PVC, in particular, is considered particularly dangerous for human health because it releases toxins into the atmosphere. So what measures does VinylPlus take to limit incineration? Is zero-incineration a target you see as desirable?

Not at all. We believe today that incineration is properly done, including for PVC waste. So we do not see zero-incineration as a desirable objective. Today, all waste is properly incinerated, including PVC waste. Today, all incinerators in Europe are equipped with mechanisms to contain the harmful emissions incineration can create. It is not at all like it was in the 90s or early 2000s.

But we do believe that, as almost all waste is recyclable, this should always be the first option. The second option is incineration, and we can say that the emissions are contained.

You say incineration is safe and emissions contained. But is this the case all over Europe or are there differences between countries or plants?

Waste incinerators all over Europe have to comply with the same stringent emission regulations. We are not concerned, and we have figures that show the level of dioxin emitted is well below regulatory limits.

But it wasn’t the case recently, you say?

No, because incinerators weren’t that good. Regarding PVC, the issue was really landfill, which is the worst-case scenario. Important sources of dioxin emissions today are landfill burning and forest fires, not energy recovery incineration.

Vinyl made a bad reputation for itself due to the presence in its composition of vinyl chloride, which is a known carcinogen. So what are the alternatives? Can the most hazardous substances in vinyl be substituted at all for safer ones? You mentioned cadmium and lead but are there more you’re planning to substitute in the future?

There are several questions here. First of all, VCM is the monomer of the PVC polymer. So for years PVC plants have been taking measures to avoid  release of VCM into the atmosphere.

Now, we have decided to substitute some of the additives in PVC voluntarily, like cadmium and lead – we have never been legally bound to do this.

So it is one thing to phase out chemicals but we are also investing a lot, looking at the future. It is not always easy to substitute chemicals. This can lead to new problems if it is not properly researched. And we are working with the additive producers to proactively identify the critical substances and explore alternatives.

Under REACH, more and more chemicals will be put on the list of harmful chemicals, so we have to find safer alternatives. There are a lot of on-going studies, particularly in flexible PVC, moving from classified phthalates to alternative plasticisers.

Do you have a phase-out plan for phthalates?

DEHP is mostly gone now. That is a chemical that is hardly used any more as a plasticiser. There are others that are used, like DINP, which is not classified and is safe. With any chemical, regulation can happen at any time depending on what studies come out. But the plan is certainly to move in the direction of safer additives for PVC in general.

How many substances are we talking about, and how many do you think can be substituted, very broadly speaking? Are we talking dozens, hundreds….?

I cannot answer that question because, for the time being, we have substituted all those of most concern, voluntarily. DEHP use decreased dramatically as soon as it was classified. It was very much the focus of the stakeholders.

But the market can change very quickly. When there are other safe chemicals available, this can also cause an automatic switch. It is interesting to look at this, especially to see the way this industry is evolving inside Europe. Outside Europe, DEHP is still widely used in some countries.

This means we still have to manage these chemicals so they do not find their way back into Europe in imported products. This is why traceability is so important in recycling.

One of the issues with REACH is the trade aspect, and DEHP may be a case in point. If these chemicals are not allowed in Europe, then I suppose products containing them cannot be imported?

REACH authorisation does not impose any import bans on articles, but importers have to provide notification of such chemicals.

If European producers can’t use those substances but they can still be imported, is this not unfair competition?

That is why it is important to do these substitutions in a proper way, in order to preserve business and give companies time to get properly equipped for the change.

This way companies in other countries can follow the European standard. But if bans are handed down too quickly there is no time for businesses to manage them.

Is this happening, as far as you can see? Is Europe setting the standard for the rest of the world?

For the time being, the rest of the world is not following our lead on DEHP. This chemical will disappear from the European market and then, of course, imports will also become questionable. Then maybe it will trickle down to other countries.

But it will not happen all at once. So we have to make sure our industry is prepared, including in the way it deals with end of life of products, to control this question.

Does the REACH label in Europe help your competitive position? If you go to a buyer and say that your products are now REACH certified, does it help on the sales side?

I cannot really say if there is a direct link for the industry between sales and REACH compliance.

REACH is a lot of effort for the industry. It helps industry to put its house in order, but it is really bureaucratic and it costs a lot of money. But I am sure that it is working and it will help to give us a clear understanding of what is used. And maybe it is a way to move to a toxic-free environment in the future, which is what we all wish to see.

IKEA claims it no longer using PVC in its furniture and textiles since the early 1990s. Others are following the example. Do you expect your market to shrink over time, in Europe at least?

We know that improving reputation takes years. Making the journey towards sustainability, which we in the PVC industry began 15 years ago, takes time and effort.  We are making progress, but we will not change our reputation in one day.

So has this damaged your reputation?

Yes, and it is a shame that they [IKEA] seem so closed to the improvements we have made. But we believe this will change in the future and it is our objective to be fully accepted by retailers and consumers.

We have made extremely good progress, including a great step in 2012 at the London Olympics, which were called the “most sustainable games ever held”. I guess you know that PVC was banned at the Sydney games in 2000, so this was quite harmful to our reputation.

We had to work on that a lot, and we worked with the London authorities when they selected their building materials and their applications, and in the end they used quite a lot of PVC in London. It was used in the main stadium roofing, in flooring, also mainly in non-permanent buildings. The reason why they took the decision to use PVC again was because we were able to show the progress we had made in moving away from heavy metals and using alternative plasticisers to DEHP.

Also the way we were able to guarantee the take-back and re-use of a number of structures, like the flooring of the basketball arena, which was completely reclaimed and used in a number of school floors in the UK.

For us this was a great step. Since then, PVC has been used more and more in sports infrastructure. Most of the new sports stadiums in Europe now use more PVC. It is a question of safety, environmental performance, energy savings – the way we produce PVC today uses much less energy than it did in the past. And the architects that build these new sports stadiums look at these materials. PVC is already the most-used plastic material in construction but it is growing and gaining acceptance again.

This is a kind of rehabilitation process you’ve been going through. When do you think you will reach the end of that journey? Will it be years of will it be decades?

The next step is 2020, to reach our target of recycling 800,000 tonnes of PVC and to achieve our energy reduction goals. Then we have to consult stakeholders again, take their advice and criticism, consult other actors in industry and refine and improve the programme so we can gain full acceptance as a sustainable material for the future.

I cannot say it will be 2020 because it is really ambitious. We know from experience that to completely change a sector’s image takes a long time. If it’s 2025, then great. The most important thing is not the date but to get the industry working together to increase the sustainable performance of this material.

This is one of the very few voluntary industry commitments in Europe that are working, delivering success and being openly communicated.

This says a lot about the other voluntary industry commitments…

At least that’s what we’ve been told: we are open, transparent and credible. We accept criticism and we know we are not perfect, but we are moving towards our goal. We are very proud to have been recognised by the UN as an industry that is producing real results with voluntary targets.

Our voluntary commitment is registered under the UN sustainability commitment system, we are part of different UN bodies, like the Green Industry Platform, UNIDO and so on. And they use us as an example around the world of how it is possible to work together as a value chain, partner with others, to set and deliver targets in a credible and transparent way. It helps us to have this recognition.

 

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