• What are persistent organic pollutants (POP’s)?
• How do the recent changes to the hazardous waste regulations impact you?
• What are the implications of POP’s in waste electrical and electronic equipment (WEEE)?
• What does this mean for the re-use and recycling industry?

Persistent Organic Pollutants (POP’s) are potentially hazardous organic substances which can impact the environment and human health if they escape. Chemical have historically been used in plastic for electrical items due to their flame-retardant properties.

Legal aspect

Many items of WEEE meet the criteria for hazardous waste under the Hazardous Waste Regulations 2005, most common are fluorescent light tubes and cathode ray tubes. Hazardous WEEE should be segregated from general WEEE for specialised collection and treatment.

The Hazardous Waste Regulations were amended 2019 to take into account the revised EU Regulation on Persistent Organic Pollutants (POPs).  The new legislation sets tougher controls on chemicals historically used as flame retardants as well as other potentially hazardous substances. 

Research carried out by the Industry Council for Electronic Equipment Recycling (ICER) suggested that levels of POPs present in common WEEE plastics are actually higher than previously thought. High bromine levels that could exceed the POPs Directive threshold can be present in the following electronic plastics:

• Plastic from cathode ray tube (CRT) display units
• Flat panel displays
• Small mixed WEEE
• Fridge compressors

Further to those, tests have been taking place to determine the presence of POPs in cabling.

Issue for the WEEE reuse and recycling industry

The new legislation sets maximum concentration levels for POPs in waste materials to levels that are below what have been commonly used in products in the past.  Many items, in particular Small Mixed WEEE, Cathode Ray Tube TVs and Flat Screen TVs, could contain levels of POPs that effectively render them hazardous.  Most of these items which previously could be reused or recycled must now be incinerated. 

Implications to the WEEE reuse and recycling industry

We are waiting for guidance from SEPA around this.

The legislation will result in a need for greater sorting and separation of what is now deemed potentially hazardous plastic derived from WEEE.

In practice, the new legislation means that some plastics from WEEE which would previously have been recycled, will now be destroyed by incineration (or potentially other high temperature processes like a cement kiln). Bromine separation technologies may be used to separate these POP containing plastics from other plastics and wastes. The latter may then be suitable for recycling.

It is anticipated that this could add significant cost to the treatment of waste electrical and electronic equipment, as hazardous waste materials are subject to greater regulatory controls than non-hazardous waste and due to more limited treatment options.

Recycling industry

Recyclers of WEEE have highlighted that plastics recycled from the WEEE stream such as computer cases had been in high demand, and they believe that concern about POPs is overstated and would prevent recycling.

Does it make sense to burn plastics which could have an alternative route?

The idea of plastic from the backs of television being seen as hazardous is also worrying exporters of refuse derived fuel. The RDF Industry Group concerns are that this would potentially mean that RDF containing these plastics should be classed as hazardous if the plastics were not covered by the exemption for household WEEE.

An additional concern pointed out by the industry was about the impact on recycling rates with the potential that some target rates may now not be achievable.

Reuse industry

There is still uncertainty on the impact of the POPs Legislation on the reuse industry.

The EA has stated that waste display devices and Small Mixed WEEE cannot cease to be a waste, or be reused, unless it is demonstrated that POPs are not present in a particular device or item of equipment. The reuse industry is expressing their concern as this could bring the reuse market for display and small items of WEEE to a close. 

In addition, it is not clear how this would impact on WEEE reuse at civic amenity sites and charity shops. Although the reuse industry did point out that the risk of spreading POPs is low as it is ‘encapsulated in the plastic’, and can only be released upon waste treatment. This means that reuse of items that may contain POPs would not create any risk of harm as the integrity of the plastic is not compromised during testing and repair.

How can Albion help?

This will impact businesses including;

• Metal recyclers,
• Recyclers of IT equipment and others accepting WEEE with POPs
• Local authorities which handle WEEE at recycling centres

Albion can help to assess the implications of this legislation through;

• Review your activities on the handling of WEEE, licences and/ or permits and cross check against the POPs legislation
• Identify areas of non-compliance
• Review your data and estimate potential impact on recycling rates (in case of LAs)
• Estimate potential impact on costs based on required method of disposal to meet regulations
• Identify options for management and classification of materials.