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12 TECHNICAL BULLETIN

Version: 31/03/06. To check if this is the current version visit www.plasticseurope.org

Classification and handling of FRP within the current EC legislation

Introduction The has developed a set of directives concerning waste control. It started with the introduction of the Waste Framework Directive (75/442/EEC) in 1975. Additional related documents include 91/156/EEC (which is an amendment of 75/442/EEC) and 91/689/EC (The directive). This Technical Bulletin gives a short overview of the current EU waste legislation with respect to the classification, shipment and disposal of FRP (Fibre Reinforced Plastic) waste. It is offered as an aid to FRP companies in their activities in complying with their legal responsibilities associated with waste handling.

Please note:

This Bulletin is simply a guide and not an interpretation of the law. All local and national legislative regulations End-of-Life FRP components must be read and understood. The bulletin is offered Lo in good faith and no liability can be accepted in The European waste list 2000/532/EC consequence of action taken by any regulatory How to classify waste within the EU waste legislation? authorities associated with compliance to the EU The basis for the classification of waste is its origin. In

Directives and the resultant national regulations. the European Waste List (Commission Decision

2000/532/EEC), waste is always categorized with a 6-

Waste Classification digit waste classification code. The first two digits give

the origin of the waste. In further subcategories the

Terminology waste and its origin are defined more precisely.

Waste is any substance that those in possession intend to discard or are required to discard. Fibre A s the Waste Framework Directive requires that waste

Reinforced Plastics are often referred to as composite be classified by type and by source, FRP waste can be materials or composites. However, with respect to EU classified under several codes of the EU Waste List, current waste legislation, it is best to avoid the term depending upon whether or not the waste is generated ‘composite’ waste because the only reference to from the moulding shop, or is end-of-life waste from ‘composites’ waste refers to complex mixtures of vehicles or agricultural use or chemical plant use for chemicals and sludges from various processes, which example. The composition of the waste governs the have nothing to do with reinforced engineering classification as either hazardous or non-hazardous materials. We will therefore consistently use the term waste and determines how the waste will be regulated

‘FRP waste’ throughout this document. and how its treatment will be managed, including trans-border shipment control. The first task when considering specific FRP waste is to define it within the broad classifications as set out in A ny waste category of the EU Waste List marked with the European Waste list for hazardous and non- an asterisk (*) is considered as a hazardous waste hazardous waste. Waste is identified with a six-digit pursuant to the Hazardous Waste Directive code from within the EC waste list. Any type of waste, 91/689/EEC (Art.1). The list takes into account, where whatever its source, is definable with one of the 6-digit necessary, limit values of concentration. If a waste is codes within the waste list. identified as hazardous, because it contains certain dangerous substances, the waste is hazardous only if Once the waste has been coded then other EC the concentrations of the substances are such that the Directives can be used to determine how to waste presents one or more of a list of properties in ship/transport or dispose of it. These include the Hazardous Waste Directive. regulations about trans-border shipment of waste, and of waste. In addition, industry For example, if the waste is ‘virgin’ FRP, from a FRP specific Directives could apply with specific reference moulding shop, then, there will be a chapter for it in the to , e.g. the End of Life Vehicle Directive or waste list under: the Directive on Waste of Electronic & Electrical Chapter 07, ‘waste from organic chemical processes’. Equipment.

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12 TECHNICAL BULLETIN (continued)

The sub-category is 07 02, ‘ from the H8 ‘corrosive’ substances. Manufacture, Formulation, Supply and Use (MFSU) of H9 ‘infectious’ substances. plastics, synthetic rubber and man-made fibres’ H10 ‘toxic for reproduction’ substances. The sub-sub-category is 07 02 13, ‘plastics waste’. H11 ‘mutagenic’ substances. Since this category 07 02 13 is not marked with an H12 substances and preparations, which release asterisk (*) it can be classified as non-hazardous toxic or very toxic gases in contact with water, waste and, therefore, shipped and disposed of air or acid. according to the EC Directives for disposal of non- H13 substances and preparations capable by any hazardous waste. However, end-of-life FRP means, after disposal, of yielding another components could, in some instances, be substance, e.g. leachate, which possesses contaminated with dangerous substances exceeding any of the characteristics listed in the above the threshold as set out in the Hazardous Waste ‘H’ categories. Directive and their waste classification will be subject H14 ‘ecotoxic’ substances and preparations to the waste source and the contaminant. Details about the assessment methods and threshold There are more references to plastics in the European concentrations of the dangerous substances can be Waste List. Relevant for FRP waste are the following: found in Annexe III of the Hazardous Waste Directive 91/689/EEC. Category 12 01 05, Waste from shaping and physical waste and mechanical surface treatment of metals and Other considerations regarding FRP waste plastics - plastic shavings and turnings. This category Once the category of FRP waste from a particular is possibly applicable for waste from machining of source has been established then issues of shipment thermosetting components. and disposal have to be considered. Since FRP waste Category 16 01 19, Waste not otherwise specified – from whatever source can, most often be classified as end-of-life vehicles - plastics. non-hazardous, it simplifies the requirements with Category 17 02 03, Construction and respect to shipment and disposal. - plastic. Category 17 02 04* (M), Construction and demolition Waste Shipment waste – wood, glass and plastic The following waste-shipment regulations apply to This category could possibly be applied to chemical FRP waste: process plant equipment contaminated with hazardous chemicals. • EC Waste shipment regulations (259/93/EEC and Category 19 12 04, Waste from EC regulation number 2557/2001) facilities - mechanical treatment of waste - plastics and rubber. When FRP waste is disposed of in the EC country of Category 20 01 39, Municipal waste – separately origin then the EC trans-border shipment of waste collected fractions – plastics. regulations does not apply. Only when waste is being shipped to another country for disposal do these regulations need consideration. In any event, FRP, Hazardous property assessment non-hazardous waste will present less of a problem for If a waste category is marked with an asterisk, one or shipment than hazardous waste. more from the hazardous properties H1 to H14 of the Hazards Waste Directive apply: The shipment regulations do bring into consideration the mineral content of the FRP waste because the H1 ‘explosive’ substances. question of waste classification for shipment purposes H2 ‘oxidising’ substances. depends upon its composition. If the mineral content of H3A ‘highly flammable’ substances the waste is more than 50% by weight then it could, (flash point of 21°C). possibly, be considered as mineral waste for shipment H3B ‘highly flammable’ substances purposes. Waste however containing more than 50% (flash point 21° to 55°C). resin (organic) would be considered as organic waste H4 ‘irritant’ substances causing inflammation on for shipment purposes. contact. H5 ‘harmful’ substances involving limited life risk • The Basel trans-boundary shipment of by inhalation, ingestion or skin penetration. waste convention H6 ’toxic’ substances involving serious, acute or chronic health risks or even death by This convention controls the trans-boundary shipment inhalation ingestion or skin penetration. of hazardous wastes and their disposal.1 When the H7 ‘carcinogenic’ substances, which may induce FRP waste contains principally organic constituents cancer or increase its incidence by inhalation (over 50% by weight), then it is considered to be non ingestion or skin penetration. hazardous for shipment across country boundaries –

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category B3010, in Annex IX of the Convention, unless Non-hazardous waste for landfill they contain Annex I material to an extent causing 1 NB: 1. The does not deal with non- them to exhibit one or more of the Annex III hazard hazardous waste 2. For the purpose of the Basel characteristics. Other possible categories for FRP Convention, the definition of disposal encompasses waste are Annex IX / B2020 and B4020, both operations which may lead to , recycling, reclamation, direct re-use or alternative uses – See Annex classified as non-hazardous. In case FRP waste IV of the Convention. contains Annex I material to an extent causing them to exhibit one or more of the Annex III hazard From the European Waste Catalogue it has been characteristics, categories A3050 or A3120 may be deduced that most FRP, provided that they are applicable. completely polymerised, can be classified as non- hazardous waste 1 and will, therefore, have access In summary, relevant Basel Convention Annex VIII and to for non-hazardous waste, as long as the IX entries for FRP waste falling under the scope of the national legislation transposing the LF Directive still Convention are: allows the land-filling biodegradable or organic waste. B 3010 Solid plastic waste

FRP waste cannot be classified as Possibly also: because it contains an organic component, which means that it will be considered as ‘bio-degradable’ B 2020 Glass waste in non-dispersible form or organic even though it may take decades or, B 4020 Wastes from production, formulation possibly, centuries to totally (bio-)degrade [NB UV and use of resins, degradation or any other oxidation has also to be A 3050 waste from production, formulation considered as a lack of inertness]. and use of resins A 3120 fluff – light fraction from shredding Even FRP waste, such as SMC/BMC waste, which contains a high level of inorganic components (fillers A= hazardous waste (Annex VIII) and B = non- and glass fibres) will have to be declared as non- hazardous waste (Annex IX). hazardous biodegradable/organic waste (e.g. category 07 02 13, 17 02 03, 20 01 39 etc., depending upon the waste source, within the EC Landfill Waste Directive) for landfill purposes. The EC Landfill Directive (1999/31/EC) encourages and recovery, including recycling, Hazardous waste initiatives. There are targets to progressively reduce FRP waste containing hazardous substances or the level of going to landfill, to materials above the threshold levels must be treat most waste before they are land filled, to ban land examined, with respect to the threshold levels of filling of liquid wastes, certain hazardous wastes and to such additives, within the H1 to H14 list of Annex III ban the co-disposal of hazardous and non-hazardous of the EC Hazardous Waste Directive. waste. Under many national legislations, the land-filling restrictions apply to organic waste (i.e. they If it appears that the waste is hazardous, then it may unambiguously encompass plastics waste) and some only be land filled in a site designated for hazardous of them have already totally banned organic waste waste provided it does not contain any components land-filling for some time. The EC Landfill Directive banned from landfill under the EC Landfill Directive distinguishes three separate classes of landfill: and its transposition into national law. [NB It may also be disposed of by incineration / See 3.3] • Inert waste • Non-hazardous waste Waste FRP from chemical plant applications may be • Hazardous waste contaminated at a level, which could change its classification, with respect to the landfill Inert waste requirements, from non-hazardous to hazardous. Includes amongst others waste glass based fibrous Such waste FRP should be evaluated via appendix materials, concrete, tiles and ceramics, etc. Since FRP C of the EC Waste Directive ‘Hazardous Property contains organic material the inert category is not Assessment’ prior to disposal. applicable to the landfill of FRP. It is possible, however, that waste recovery from FRP incineration, in the form of glass fibre and inorganic fillers, would generate inert waste that could be used for recovery or for landfill purposes. This residual incineration waste should fit within the definition of inert waste given in the LF Directive.

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12 TECHNICAL BULLETIN (continued)

Incineration substances, heavy metal based catalysts or other The EC Incineration Directive (2000/76/EC) sets substances – (due e.g. to absorption in the GFR minimum requirements for waste (co-) incineration plastic item during use-) don't exceed the limit values plants. It includes a list of specific provisions for the defined in the Dangerous substances or in the (co-)incineration of hazardous waste (e.g. substances Dangerous preparations or in the Waste Shipment with which it cannot be mixed, and precautions to be Directives when applicable. taken in handling the waste) and encompasses the 1 co-incineration of waste on its place of production. The Provided that the FRP waste is fully cured. Directive gives detailed requirements about items, such as: Mixing of wastes It should be noted that mixing of wastes, (e.g. to reach concentrations of dangerous substances lower than • Which waste is excluded from the scope of the Directive - (Art.2) the admissible limit values or to meet acceptance • Acceptance criteria and reception procedure - criteria), is prohibited by various provisions of the (Art.5) above mentioned Directives. • How the incinerator plants shall be operated in order to achieve a required level of incineration Relevant EU legislative documents regarding FRP waste EEC The Dangerous (e.g. permit and conditions for non-hazardous or for hazardous waste) (Art.6) substances Directive 75/442/EEC The Waste Framework Directive • Air emission levels (including mandatory 89/369/EEC The Municipal Waste Directive measurements) – (Art.7, 10, 11) (new MSWI - Repealed by 2000/76/EC) • the quality of water discharges from cleaning of 89/429/EEC The Municipal Waste Directive exhaust gases – (Art.8) (existing MSWI - Repealed by 2000/76/EC) • what to do with residues from the incinerator 91/156/EEC Amendment of Directive 75/442/EEC on waste process in terms of their amount and harmfulness 91/689/EEC The Hazardous Waste Directive 93/259/EEC The Regulation on Trans-border Shipment - (Art.9) of Waste 94/67/EEC The Hazardous Waste Incineration Directive FRP waste can be incinerated provided the emissions 1999/31/EC The Landfill Directive from the waste issuing from the incinerator stack are 1999/45/EC The Dangerous Preparations Directive 3 within the emission targets set out in the Incineration 2000/76/EC The Incineration of Waste Directive Directive. In addition, the waste must be able to supply 2000/53/EC The End-of-Life of Vehicles Directive sufficient fuel to enable completion of incineration 2000/532/EC List of Waste in relation to the Waste without the addition of other fuel except in the form of Framework Directive 75/442/EEC (EU Waste list) other waste. Hence, where the type of FRP does not 2002/95/EC The RoHS Directive (restriction of use of contain sufficient energy for complete combustion it hazardous substances in E&E equipment) can be incinerated via a co-incineration process where 2002/96/EC The WEEE Directive on Waste of Electronic is incinerated together. and Electrical Equipment

There are constraints on how the grate ashes (as And their subsequent amendments opposed to flying ashes, always a hazardous waste) from incinerators is treated but once classified with respect to the hazard it may present, it can be either land-filled or recovered as material. Residual incineration waste (or grate ashes) from FRP (co-) This publication is intended for guidance only and while the incineration, containing inorganic filler and glass fibre information is provided in good faith and has been based on the best information currently available, is to be relied upon at the residues, could, if properly treated, be classified as user’s own risk. The information contained in this document is inert waste for recovery or landfill purposes. provided in good faith and, while it is accurate as far as the authors are aware, no representations or warranties are made with regards to its completeness and no liability will be accepted for damages of In some industry specific EC Directives, such as the any nature whatsoever resulting from the use of or reliance on the End-of-Life Vehicle (ELV) Directive, incineration is an information contained in the publication. option with and recycling designated as the route for waste materials from vehicles. Similar legislation is applicable to the Electrical and Electronic Component Industry.

PlasticsEurope Important reminders Avenue E. van Nieuwenhuyse 4 Presence of substances rendering the waste B-1160 Brussels, hazardous Telephone + 32 2 676 1732 Care has to be taken that substances susceptible to Fax +32 2 675 3935 render the waste hazardous, (e.g. un-reacted Email [email protected] www.plasticseurope.org

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