Waste Framework Directive
What is the European Waste Framework Directive (WFD)?
The European Waste Framework Directive is dealing with materials out of “end-of-life products”. Its aim is to decrease the impacts of waste on the environment and human health by installing appropriate waste management systems.
The revision of this instrument was envisioned for 2015, however, the proposal has been dropped by the European Commission. A new proposal has been announced for 2015.
How does it concern our industry?
Once our products have reached their end of life they should be recycled because recycled material is highly valuable and can be used to produce new windows. According to the current WFD once a product has reached the end of its life it will become waste. Hence, everyone dealing with this waste material needs to obtain a waste handling permit which is subject to very strict criteria and conditions aiming at the prevention of adverse impacts on the environment and human health. While it is not disputed that such a prevention is necessary there are several burdens attached to this requirement of which some are particular to our industry:
It has been acknowledged in the Directive (Art.6) that waste can cease to be waste if certain criteria are fulfilled such as recycling. However, the exact criteria need to be outlined for each material via a delegated act. While the Joint Research Centre is working on such criteria for plastics these have not yet been published and were in fact delayed several times already. Accordingly, it is currently unclear when plastic materials fall under the waste legislation and at what point in time they start falling under product legislation instead. Obtaining a waste handling permit is a heavy burden to recyclers who process the old windows into granulate that can be used to produce new windows. It is costly and a huge administrative burden. Moreover, in some countries even the converter (i.e. the profile manufacturer) needs such a permit as the recyclate is still regarded as waste in these countries. This situation impedes the well-functioning of the internal market due to diverging legal situations in the Member States. Furthermore, legal uncertainty is detrimental to economic investments: recycling activities become less attractive if costs associated to recycling are high and uncertain.
EPPA finds the concept of “End-of-Waste” to be ill-suited for its industry. In a circular economy materials have different life cycles than products. While a product will reach the end of its life at one point the materials it is composed of will start their next life cycle. Hence, materials that have completed their first life cycle will serve as a raw material for a new product. It follows that materials have a certain (monetary) value from their formulation up to the point where they are incinerated (or landfilled). This exact value will, amongst others, depend on the properties of the individual material and the amount of life cycles it has already completed. It should therefore be acknowledged that some materials, particularly long living plastics, serve as secondary raw materials in-between the ‘grave’ and ‘cradle’ stages of the products they form part of. Following this logic and in the sense of the circular economy the creation of a legal regime for secondary raw materials should be envisioned. The exact properties of these need to be defined. Please read our position paper (link) for more information.
A further problem related to the WFD is the dealing with legacy additives. Currently, none of the existing European legal frameworks sufficiently solves this problem which is further described in the “Recycling” section of this website.
What are our proposals?
EPPA has the following proposals in order to improve this piece of legislation:
Landfill ban in 2025:
As outlined above PVC is a material that remains valuable once the product it forms part of is no longer used. EPPA is strongly in favour of a landfill ban in order to avoid wasting this valuable material. A landfill ban should encourage the putting into place of collection and recycling systems. To the contrary it should be no means lead to an increase of incineration and energy recovery operations. While it is acknowledged that, in the short run, it is less burdensome to build incineration plants than to organise collection schemes, this practice will in the long run be detrimental to the circular economy and its material life cycles. In this context it should also be noted that the WFD itself lines out the priority of recycling over energy recovery and incineration (see graphic).
The concept of secondary raw materials should be included into the WFD.