Hazardous Waste Europe is a member of the Zero Pollution Stakeholders Platform. During the High Level Launch Meeting, on December 16th, our President delivered the HWE’s core message: Hazardous Waste Europe is a EU business association of hazardous waste operators present on the whole value chain of hazardous waste management, from collection to final treatment. We treat pollution of all kinds by providing hazardous waste its appropriate treatment. It can be regeneration, recycling, material recovery, hazardous waste incineration, physico-chemical treatments specifically of wastewaters, soil remediation, and hazardous waste landfilling. We operate IED and SEVESO installations and we have expertise in the treatment of the most harmful chemicals including those internationally recognised like POPs and mercury. As we stand at the end of the value chain, we definitively act as the last bastion to destroy toxicity, limit dispersion of pollutants in the environment and we ensure non-toxic recycling. It is our responsibility. Our existence results from the necessity to manage all unavoidable hazardous waste inherent to our way of living even though we expect it to be much more sustainable and resilient in the future. Consequently and according to the zero-pollution hierarchy, our commitment in the platform would mainly bring expertise in Eliminate & Remediate and Minimise & Control. HWE expects the Platform to develop operational tools supporting stakeholders benchmarking their level of implication in reaching the 2030 and 2050 goals. The list of actions foreseen by the Commission to meet these goals is very ambitious and HWE endorses it and is already active in many of them. According to this action plan and in consistency with the Group specific’s tasks and our expectations, we would advocate 3 broad initiatives: drawing up guidelines to address the risk of contamination of end-of-life materials and sewage sludges impeding high quality recycling and perpetuating the presence of substances of concern in the material loops, waters and soils. It shall encompass good practices in order to comply with the Regulation on POPs but also to ensure that other legacy substances and substances of very high concern are appropriately extracted from the wider economy, assessing in a much easier way real environmental performances of, at least, IED installations in terms of emissions to air and water developing a comprehensive methodology which can apply in all circumstances in order to address efficiently and as fast as possible issues when new substances are identified as a threat to the planet. This will steadily occur in the future as we get more and more knowledge on chemicals. Industries, Authorities and NGOs need clear requirements and stable decisions to take the right decisions. PFAS is a good case study. It is a deep honour to sit in this platform, to be part of the solution and see our expertise acknowledged. We are eager to share our operational experience to discuss and implement the best practices to create a zero pollution ambition for a non toxic environment.
Revision of the CLP regulations: our proposals to keep on track on the non toxic environment
The Chemicals strategy aims at strengthening the EU legal framework to address pressing environmental and health concerns through the revision of the REACH and CLP Regulations. Following the impact assessment and roadmap, the Commission consulted citizens and stakeholders as part of the targeted revision of the CLP regulation. Our particular position at the interface between products, chemicals and waste has given us specific experiences to share concerns and proposals on the revision of the CLP regulation in order to protect health and the environment and pave the way towards a non toxic environment. You will learn below our main points: Our main challenge is to acknowledge the distinction between waste and products, justifying different approaches between them and the relevance to keep separate classification. As stakeholders acting at the very end of the economic chain, our experience demonstrated that once a product becomes waste, it is not always easy to know for sure its final destination. A product is designed for a known specific use, with a use scenario, making it relevant to apply a risk based approach that will validate that there are no adverse risks for this use. On the contrary, a waste could not be oriented for sure towards one expected route and many different choices are available between recycling, recovery or disposal, depending on the quality of the waste, the market and many other contextual reasons. Consequently, it could be difficult to ensure that the totality of the waste stream will follow a route comprehensively assessed under the CLP rules, making it relevant to adopt an hazard based approach based on the intrinsic properties. Propose a comprehensive definition of substances of concern to encompass those identified under REACH as SVHC, substances prohibited under the Stockholm Convention (POP), specific substances restricted in articles listed in Annex XVII to Reach as well as specific substances regulated under specific and sector legislation (RoHS, etc.). The list should be regularly updated by ECHA on the basis of new available results and take into account new and emerging chemical hazards such as EDC, nanomaterials, and microplastics. Adopt a grouping approach as similar substances are likely to present similar threats. Integrate new hazards to take into account that new, emerging and also suspected chemical risks pose a threat to health and the environment. This problem should be addressed by introducing specific hazards to address this risk, and thus considering chemicals substances that are concerned by this hazard – but are not part yet of a comprehensive framework or not yet regulated (for instance, endocrine disruptor hazard). To apply with the precautionary principle, considering distinction between “known” and “suspected” categories would make sense. Ensure information and traceability on the whole chain. The CLP has impacts on products, chemicals and waste legislation. It is therefore crucial to ensure information and traceability of streams throughout the value chain and to valorize available tools towards this end, notably the SCIP database that would allow sharing of information between the whole chain of actors, until the waste treatment operator.
Taxonomy and hazardous waste management, Chapter #1
Hazardous waste Europe really welcomes the outcome of the draft report on the preliminary recommendations for Technical Screening Criteria (TSC) for the EU taxonomy developed by the Technical Working Group of the platform on Sustainable Finance. We fully endorse the high level of ambition in the TSCs for separate collection, transport and treatment of hazardous waste as a means for pollution prevention and control (subchapters 13.1, 13.2 & 13.3): 👍Ensure strict separation of hazardous waste from non-hazardous waste for collection & transport 👍Avoid blending or mixing leading to dilution of hazardous waste and consequences due to inappropriate treatments 👍Ban organic hazardous waste in facilities treating hazardous waste prior to hazardous waste landfilling 👍Prevent or reduce at the minimum the discharge of priority substances and priority hazardous substances in water bodies due to indirect discharge via inappropriate wastewater treatment plants 👍Avoid mismanagement of POP waste, mercury waste and problematic health care waste 👍Guaranty that facilities benefiting from derogations under article 15.4 to the IED will never be taxonomy-aligned HWE would have liked to see the same level of ambition in other sectors (at least regarding derogations mentioned just above…) whose core business is not the treatment of hazardous waste but where hazardous waste end in conditions which lead to uneven playing field with our sector dedicated to the treatment of hazardous waste. We hope that our will and our actions to do more and better for a zero pollution ambition in a toxic free environment will be rewarded one day, and why not, thanks to the taxonomy! We are a bit more reserved regarding the subchapter 13.4 on treatment of hazardous waste as a means for material recovery. The ambition is very poor here while circular economy objectives related to hazardous waste also require adopting practices ensuring decontamination from substances of concern for safe recycling and material recovery. An offer of secondary raw materials contaminated by legacy substances will never meet the demand… and consequently circularity will fail to happen! Additionally, it would have been obvious to us that battery recycling should be explicitly nominated here considering the importance of this activity in the European industrial strategy! To be continued with chapters #2 and #3… [button link= »https://ec.europa.eu/info/publications/210803-sustainable-finance-platform-technical-screening-criteria-taxonomy-report_en » type= »icon »] Download here[/button] the Draft report by the Platform on Sustainable Finance on preliminary recommendations for technical screening criteria for the EU taxonomy
IED-EPRTR-Revision – HWE’s position
[et_pb_section admin_label= »section »] [et_pb_row admin_label= »row »] [et_pb_column type= »4_4″] [et_pb_text admin_label= »Text »] The industrial emissions directive, currently under review, is a cornerstone of the EU legislation, aiming at achieving a high level of protection of the environment as a whole. It provides valuable and key provisions to prevent and control pollution arising from industrial activities and issue environmental permits in compliance with the EU Green Deal’s objectives to ensure a zero pollution ambition for a non-toxic environment. The revision of the text will be the occasion of some improvements to ensure a better coherence with the EU legislative framework and more harmonised implementation in the EU Member States. You will find attached our views on the topic in the paper attached [button link= »https://www.hazardouswasteeurope.eu/wp-content/uploads/sites/3/2021/03/2021-03-23-HWE-position-paper-IED-E-PRTR.pdf » color= »green »] HWE POSITION PAPER[/button] [/et_pb_text] [/et_pb_column] [/et_pb_row] [/et_pb_section]
A zero pollution ambition for a toxic-free environment – HWE’s position
To pave the way towards « a zero pollution ambition for a toxic-free environment », the EU Green Deal annonced the objective of the EU commission to look more systematically at all policies and regulations and adopt in 2021 a zero pollution action plan for air, water and soil. Find HWE’s proposals to ensure that our legislation and principles reach this objective of a non toxic environment : [button link= »https://www.hazardouswasteeurope.eu/wp-content/uploads/sites/3/2021/02/2021-02-10-HWE-Zero-Pollution-Ambition.pdf »] HERE[/button]