PowerPoint-Pr

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REACH RECYCLING (REACH GHS WFD - ELV
WEEE ROHS) Presentation at REPLAST
2008 Balatonfüred, Hungary January, 24th, 2008
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• Content
• Brief personal introduction
• REACH - Definitions and Requirements
• WFD (Waste Framework Directive) ELV, WEEE, ROHS
• Where do we go from here ?

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1. CV in brief1948 Ing. Leopold KATZMAYER,
born 1948 in Vienna, married, two daughters,
one of them plastics engineer as well
(Recycling)1967 finished Education as Plastics
Engineer TGM, Vienna1969 joined Gabriel-Chemie
in as RD Engineer1977 Head of Technical
Departments1984 Member of Board at the Group
Headquarter in Vienna (until 2005)1989-1991
Transfer of the Company to the current site1991
Managing Director of Gabriel-Chemie UK Ltd.
(until 2001)2003 Managing Director of
Gabriel-Chemie Hungaria Kft. (until 2007)2005
Left the operational board, changed to
Gabriel-Chemie International Holding to
work on different special projects,
e.g.REACH2007 Foundation of katzmayer
consulting, Technical Engineering Office
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Creative and InnovativeTechnical
AssistanceforPlastics TechnologyRecycling
REACH
e-mail l.katzmayer_at_aon.at Tel
43(0)2624-53601 Fax [phone]
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Current Functions

• President of VÖK (Association of Austrian
  Plastics Processors)
• Vicepresident of GfKT (Ass.for Promotion of
  Plastics Techn.)
• Vicepresident of OFI (Research Inst. f.Chemistry
  Techn.)
• Chairman of ETHIC (European Thermoplastic
  Independant Compounders and Masterbatchersa
  subgroup of EuPC, Brussels)

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• European Thermoplastics Independent Compounders

A Sector Group of EuPC
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ETHIC Members Associated Members

• Members
• AMPACET Europe S.A.
• CABOT Corporation
• CLARIANT
• CTS Cousin Tessier
• Poloplast GmbH Co KG
• GABRIEL-CHEMIE GmbH
• LATI Industria Termoplastici S.p.A.
• NORD COLOR
• A. Schulman
• POLYKEMI AB
• POLYONE Corporation
• POLYTECHS S.A.
• PREMIX OY
• RAVAGO Plastics S.A.
• TER HELL Plastic GmbH
• VIBA S.p.A.
• Polymer Chemie
• Constab

• Associated Members
• Borealis

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ETHIC Executive Committee
President Leopold Katzmayer,
Gabriel-Chemie Vice-Pres. Philippe Druot,
Polytechs Treasurer Daniele Peruzzo,
Ampacet Administr. Antti Kiikka, Premix OY
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ETHIC Activity

• ? REACH Chemicals Policy

• ETHIC activity on REACH so far results in
• Providing clarification on the Regulation to its
  members
• Detecting potential problems on its future
  implementation
• Contributing to problems-solving through its
  lobby activity
• Tool of communication on what the Compound
  Industry is and represents in Europe
  towards the European Institutions and the
  Industry in general.
• Active participation on the Commission RIPs
  (REACH Implementation Projects)
• RIP 3.2 (CSR, SDS)
• RIP 3.2-2 ? Preparations and Waste phase
• RIP 3.5 (Downstream Users)
• RIP 3.8 (Substances in Articles)

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ETHIC Activity

• ? Electric/Electronical

• WEEE (Directive on Waste on Electric and
  Electronic Equipment ) fixes short and long term
  for recycling and bans certain families of
  flame retardant.
• ETHIC in co-operation with the Technical Plastics
  WG of EuPR (European Plastics Recyclers,
  Association of EuPC) has worked on
• Feasibility of recycling/recovery percentages
• Recycling facilities
• Standards
• Revision of the WEEE foreseen in 2008 (Commission
  source)

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ETHIC Activity

• ? Flame Retardant

RoHS Directive on Hazardous substances bans
certain families of flame retardant. Recently
the EC Commission launched and Internet
consultation on the use of Deca-BDE as a flame
retardant. A previous impact assesment had
excluded this Deca-BDE from the list of ban
substances. ETHIC has participated on this
consultation. ETHIC Meetings provide updated
information on Flame Retardant use as well as on
other substances that are on the scope of future
EU legislation. In a Decision published on 15
October 2005, the EU has exempted Deca-BDE from
the EUs Directive on the Restriction of
Hazardous Substances (RoHS).  The Commissions
Decision was taken on the basis of the results of
a ten-year EU risk assessment which evaluated 588
studies and concluded that the use of Deca-BDE
does not pose health or environmental risks
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ETHIC Activity

• ? Automotive ELV/IMDS

• ELV is the Directive on End of Life Vehicles
• IMDS System has been set up by the car makers,
  originally on the basis of the ELV Directive.
• This system requires the suppliers to the car
  Industry to provide 100 disclosure of the
  composition of their substances.
• EuPC Automotive Transport Division issued a
  position paper for their members. Together with
  ETHIC, the Division set up a Working Group with
  FIAT /GM in order to reach an agreement on data
  disclosure.
• A new working group on recycling and IMDS has
  been set up in October 2004.
• ETHIC is represented in the EuPC Automotive
  Transport Division.
• ETHIC participates to the meetings of the GASG
  (Global Automotive Stakeholder Group)
• Group meets twice per year to develop the list of
  declarable substances (GADSL) that they hope will
  eventually become the international standard.

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ETHIC Activity

• ? WFD (Waste Framework Directive)

• The current revision of the Waste Framework
  Directive has important implications for the
  Compounder and Masterbatch producers in the EU
• Definition of Recycling
• As broad as possible, ETHIC affirms
• Waste Hierarchy
• By-Products
• Distinction between by-products and waste
• Definition of Secondary Raw Material
• Especially looking at REACH
• In the EU there is no legal accepted definition
• EuPC/ETHIC are creating a position paper to
  discuss with the relevant authorities (European
  Commission, European Parliament and European
  Council) the implications of the WFD for the
  plastic compounding and converting industry
• ONE VOICE and ONE VISION for the Plastic
  Compounder, Masterbatchers, Converters and
  Recyclers

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ETHIC Activity

• ?ETHIC web site
• www.compounders.eu
• ? Contact ETHIC
• info_at_compounders.eu

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What does REACH mean ?

• R egistration
• E valuation
• A uthorisation and Restriction of
• CH emicals
• REACH is so far the largest (framework) law of
  the EU.
• As a REGULATION it is immedeately and equally
  valid in all member states.
• It is focussed on SUBSTANCES and requests
• very detailed communication up and down the
  supply chain.

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Who is concerned by REACH ?

• Manufacturers (of chemicals within the EU
  territory)
• Importers (who imports chemicals into the EU)
• Downstream Users (companies using chemicals)
• Traders (of chemicals)

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Monomeres
(Stabilizers, Pigments)
(Fillers, Flame retarder)
Polymer manufacturer Virgin Polymer
Substances
Substances
Substances
May 2007
Compound Manufacturer
Compound Manufacturer
Masterbatch Manufacturer
Plastics Processing
Innercompany Recycling (by products)
ESs to be determined
Articles
MATERIAL CYCLE
USE/APPLICATION

Waste Collection (diff. Systems)
Material recycling
Secondary Material
FEEDSTOCK CYCLE
ENERGY CYCLE

End o life Plastics (several reasons)
Secondary Energy source
Incineration
(JUST ENERGY)
Municipal waste Incineration
Solution, Pyrolysis
Feedstock
ASH
(SUBSTITUTION OF OIL)
(WASTE VOLUME REDUCTION ENERGY)
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REACH RECYCLING

• Waste is out of REACH !
• Recyclates need to come back into REACH !
• Question How does this work ?
• Answer Not at all ! (under the current
  situation)
• and exactly this is the problem............

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Why does that cause problems ?

• REACH is SUBSTANCE - oriented !
• WASTE out of REACH cannot be determined as
  requested by REACH on ist way back into the
  system.
• REACH without an useful compromise, would make
  plastics recycling legally impossible
• The EU-Commission but dreams of recycling shares
  of more than 40 until 2015 !!!
• HENCE The Commission has to find an useful
  compromise

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What could be the compromise ?

• Technical Interpretation
• Political solution by ammendments ?
• EuPC u. ETHIC have warned since 2003 to avoid
  these problems before REACH comes into force.
• All suggestions to solve the problem have been
  ignored.
• Now a number of considerations are discussed for
  finding an acceptable compromise.

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Considerations

• Plastic waste could be seen as polymer based
  preparations with impurities. Polymers are
  exempted from registration and the impurities
  cannot be worst, than the currently accepted
  substances.
• Plastic waste could be seen as the average of
  known formulations in the market, hence can be
  calculated as a generic waste composition which
  is than accepted for determined uses.
• Plastic waste, if seriousely sorted, can be seen
  as a high quality approach with certain
  specification, hence acceptable for more
  sophisticated applications.
• The remaining uncertainty is the content of end
  of live plastics articles imported to the EU and
  not manufactured under REACH conditions.

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Monomeres
(Stabilizers, Pigments)
(Fillers, Flame retarder)
Polymer manufacturer Virgin Polymer
Substances
Substances
Substances
May 2007
Compound Manufacturer
Compound Manufacturer
Masterbatch Manufacturer
Plastics Processing
Innercompany Recycling (by products)
ESs to be determined
Articles
MATERIAL CYCLE
USE/APPLICATION

Waste Collection (diff. Systems)
Material recycling
Secondary Material
FEEDSTOCK CYCLE
ENERGY CYCLE

End o life Plastics (several reasons)
Secondary Energy source
Incineration
(JUST ENERGY)
Municipal waste Incineration
Solution, Pyrolysis
Feedstock
ASH
(SUBSTITUTION OF OIL)
(WASTE VOLUME REDUCTION ENERGY)
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Plastics never become Waste

• Petroplastics are inherently recyclable(Except
  Duroplastics)
• Bioplastics may be inherently compostable....(When
  intended)
• Plastics are inherently incinerable...(Except
  Duroplastics)
• Plastics hence are highly sustainable...(No
  exception)
• Plastics are environmentally safe.(When
  seriousely handled)
• Plastics are saving resources and
  energy.(Prooven facts)
• provided they are used sereousely,
  intelligently logically to the best of already
  existing knowledge!
  
  
  
• 
  
  
  
  
  

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Disclaimer

• The documents, opinions and interpretations
  expressed in my presentation, do not in any
  respect represent the official interpretation of
  the European Community Legislation. Any document
  herein has been produced for information purposes
  only. It can not be guaranteed that the extracts
  of the official legal adopted text are reproduced
  exactly. The author does not warrant or assume
  any legal liability or responsability for the
  accuracy, completeness, or usefulness of any
  information or process disclosed. The views and
  opinions expressed do not necessarily state or
  reflect those of the European Union and they may
  not be used for advertising or product
  endorsement purposes.
• The author likes to thank ETHIC, EuPC and
  specifically its
• HS-Director, Dr. Walter CLAES for all kind
  informations, trainings, slides and other efforts
  to better understand the EU-Legislation.
• This presentation has been prepared for the
  REPLAST 2008 and its participants and must not be
  handed over to third parties without the written
  agreement of the author
• katzmayer consulting, Ing. L. Katzmayer,
  January 2008

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Thank you very much for your audience and
patiency and