EERA Position Paper On Analysing WEEE Plastics - April 2013 - 0

EERA Secretariat- Address: Pels Rijckenstraat 5, 6814 DK Arnhem, The Netherlands
Tel: +31 26 3702008, E-mail: secretariat@eera-recyclers.com, Website: www.eera-recyclers.com

Pagina 1

EERA position paper on sampling and analyses of WEEE
plastics

April 2013
Introduction
The European Electronics Recyclers Association (EERA) is a non-profit
organization that promotes the interest of recycling companies who are treating
waste electrical and electronic equipment (WEEE) in Europe. EERA members
include the largest electronics recyclers in Europe who, together process over 2
million tons of WEEE.
EERA has directly been concerned by the developments of the revision of the
WEEE Directive and EERA has made several constructive proposals for this
revision. EERA has also intensively followed the debates around the revision of
the Directive for Restriction of Hazardous Substances in Electrical and Electronic
Equipment (RoHS). More information about EERA can be found on the website:
www.eera-recyclers.com.

Sampling and analyses of WEEE plastics
Proposals are being launched to analyse the de-pollution of WEEE plastics in the
first stage of the WEEE recycling process. The WEEE Directive prescribes the
removal of plastics containing brominated flame retardants. The TAC paper to
this purpose adds that this removal of plastics with brominated flame retardants
is required before the end of the recycling processes.
Taking into consideration that:
1. Poly-brominated Biphenyls (PBBs) cannot be found in plastics from E-Waste
housings and enclosures anymore. Hence no stockpile or legacy of these POP
substances need to be analysed,
2. Of the group of the Poly Brominated Diphenylethers (PBDEs) the most
frequently used substance has been Deca-BDE, a substance that is currently
not POP listed and not restricted by the EU REACH Regulation,
3. Octa-and Penta-Polybrominated Diphenylether are defined as "new POPs by
the Stockholm convention, whereby Penta-BDE has not been used in housings
of electric and electronic equipment,

Pagina 2

4. Commercial Octa-BDE (consisting of a mix of various isomers) has been used
in housings of electric and electronic equipment, but the use of Octa-BDE has
been replaced by many other types of (non-restricted) brominated and other
types of non-brominated flame retardants since the end of the nineties,
5. With an average lifetime of some 10 years it is clear that Octa-BDE is a legacy
substance with a very small stockpile left in old equipment and it can
occasionally be found in really small quantities in housings of CRT- and
professional-equipment only. Historic analytic data show that PBB and the
new POP substances Octa-and Penta-BDE cannot be found in shredded large
and small domestic appliances to any extend that makes these plastic
fractions to become hazardous material,
6. The plastics housings of WEEE are currently recycled to a large extend and
the existing best available technology is capable of reducing the levels of
brominated flame retardants to the threshold levels for both REACH and RoHS
- thus resulting in End-Of-Waste plastics that can be re-used in a large
number of durable applications,
7. Recycling of plastics from WEEE has a large carbon footprint - per metric ton
of recycled plastics from E-Waste more than 4 metric tons of carbon dioxide
emissions are prevented compared to the production and use of virgin
plastics,
8. The Stockholm Convention has recognized that the environmental advantages
of recycling outweighs the environmental hazards of this small legacy of these
substances and it has listed an exemption for plastics recycling (see annex),
it is logic that there should be no requirement to sample and analyse WEEE in
the first stage of the recycling process.
More background
The recyclers of the plastics fractions from WEEE are required to recycle these
plastics to be in conformity with the EUs product legislation, which is REACH for
all product that are not used in the market of Electronic and Electronic
Equipment (EEE) and RoHS for products that fall within the category of EEE. As
the plastics recycling industry is capable of removing the brominated flame
retardants containing plastics to levels that render the material REACH and/or
RoHS compliant, there is no need to insist on incinerating plastics that might
contain brominated flame retardants, as some authorities in Europe are
suggesting. This will almost certainly lead to large scale cost increases for the
recycling industry and is in full contradiction with the European strategy to
develop a recycling society.
Sampling and analyses methods need to be applied by the plastics recycling
industries to prove REACH or RoHS compliance of the products that they are

Pagina 3

producing. EERA absolutely supports the current legal framework of the WEEE
Directive, REACH and RoHS and is convinced that this framework will continue to
effectively reduce the stockpile of restricted brominated flame retardants.
The European recycling community must have a level playing and should be kept
cost efficient. Only in this way large quantities of plastics can be recycled. Adding
unnecessary sampling and analyses costs to the recyclers will result in more
material to disappear in informal recycling channels.
In order to control the risks of restricted BFRs, EERA suggests that the control of
the downstream distribution of the fraction of CRT housings only would be the
best method to control the risks of restricted brominated flame retardants.
Additional analyses do not add value, as we already know that BFRs including
some legacy of restricted BFRs are concentrated in this fraction.
The call for incineration of plastics if no analyses on BFRs are made on the basis
of the precautionary principle has no solid background. Such an approach leads
to a situation where recycling targets which are legally required by the WEEE
Directive cannot be achieved.
It is agreed a long time ago, that the brominated flame retardants need to be
removed before the end of the recycling processes. This being the case, there is
no need to remove the BFR containing plastics in a de-pollution step earlier in
the process.
EERA looks forward to a fundamental and constructive debate between the
stakeholders on this theme.

For more information please contact:
EERA Secretariat, info@eera-recyclers.com

Pagina 4

!""#$ & ' ()*"+#, -$#./+01"2 3+145617. 81"9#"+01":
Register of specific exemptions for the chemicals listed in the Annex A

!"#$%&'(')*+,"-./ "1,"& $-) ,"+1$%&'(')*+,"-./ "1,"&
Party Purpose(s) of use
Estimated
quantity
of annual
use
Reason(s) for exemption
Duration of
the
exemption(s),
if less than
five years
Remarks
Canada In accordance with
Part IV of Annex A
(Decision SC-4/14)
Not known
at this time
While manufacture, import and use
of C-OctaBDE commercial mixtures
are prohibited, some articles
containing this commercial mixture
could still be in use in Canada and
some may be recycled.
Not provided Paragraph 1(b) of Part IV
does not apply to Canada as
Canada has not set
levels/concentrations on
articles for permitted use,
import or manufacture at this
time.
Czech
Republic
In accordance with
Part IV of Annex A

European
Union
In accordance with
Part IV of Annex A
Unknown While the production, placing on the
market and use of
hexabromodiphenyl ethers and
heptabromodiphenyl ethers are
prohibited, some recycling articles
containing these substances and
produced before introduction of the
ban cannot be excluded.
None
Japan Recycling Automobile
Shredder Residues
(ASR) to Refuse
Paper and plastic
Fuel (RPF).

Recycling ASR to
Recycled Sound-
Proofing Products
(RSPP).

Recycling plastics
from used specific
home appliances (air
conditioner, television
sets, refrigerator,
freezer, washing
machine and clothes
dryer) and personal
computers to
constriction material
and daily necessities
N/A Recycling of ASR is an obligation for
automobile manufacturers and
importers under the Law for the
Recycling of End-of-Life Vehicles. It
is necessary to enable recycling of
ASR to maintain appropriate
management system of End-of-Life
Vehicles. Recycling of ASR is
operated in environmentally sound
manner under the law.

Recycling used specific home
appliances is an obligation for home
appliance manufacturers and
importers under the Home Appliance
Recycle law. It is necessary to
enable recycling of plastics from
used specific home appliances to
maintain appropriate management
system of the used specific home
appliances and establish a sound
material recycle society. Recycling
of such plastics is operated in
environmentally sound manner
under the law.

It is difficult to estimate the
quantity of annual use of the
chemicals listed above,
because of uncertainties and
lack of information of their
use to automobile parts and
the specific home appliances
in the past.

Approximately 500,000 tons
of ASR which might contain
the chemical listed above is
recycled annually.

of plastics from used specific
hove appliances which might
contain the chemicals listed
above are recycled annually.

Pagina 5

!"#$%&'(')*+,"-./ "1,"& $-) ,"+1$%&'(')*+,"-./ "1,"&
such as hangers and
bookends.
Recycling used personal computers
is an obligation for personal
computer manufacturers and
importers under the law for the
Promotion of Effective Utilization of
Resources. It is necessary to enable
recycling of plastics from used
computers to maintain appropriate
management system of the used
personal computers and establish a
sound material recycle society.
Recycling of such plastics is
Approximately 5,892 tons of
used personal computers are
collected annually. On
average, the weight of
plastics which might contain
the chemicals listed above is
approximately 15% of total
weight of personal
computers.

Party Purpose(s) of use
Estimated
quantity
of annual
use
Reason(s) for exemption
Duration of
the
exemption(s),
if less than
five years
Remarks
Canada In accordance with
Part V of Annex A
(Decision SC-4/18)
Not known
at this time
While manufacture, import and use
of C-PentaBDE commercial mixtures
are prohibited, some articles
containing this commercial mixture
could still be in use in Canada and
some may be recycled.
Not provided Paragraph 1(b) of Part IV
does not apply to Canada as
Canada has not set
levels/concentrations on
articles for permitted use,
import or manufacture at this
time.
Czech
Republic
In accordance with
Part V of Annex A

European
Union
In accordance with
Part V of Annex A
Unknown While the production, placing on the
market and use of
tetrabromodiphenyl ethers and
pentabromodiphenyl ethers are
prohibited, some recycling articles
containing these substances and
produced before introduction of the
ban cannot be excluded.
None
Japan Recycling Automobile
Shredder Residues
(ASR) to Refuse
Paper and plastic
Fuel(RPF).

Recycling ASR to
Recycled Sound-
Proofing Products
(RSPP).

Recycling plastics
from used specific
home appliances (air
conditioner, television
sets, refrigerator,
N/A Recycling of ASR is an obligation for
automobile manufacturers and
importers under the Law for the
Recycling of End-of-Life Vehicles. It
is necessary to enable recycling of
ASR to maintain appropriate
management system of End-of-Life
Vehicles. Recycling of ASR is

Recycling used specific home
appliances is an obligation for home
appliance manufacturers and
importers under the Home Appliance
Recycle law. It is necessary to
enable recycling of plastics from
used specific home appliances to
maintain appropriate management
system of the used specific home
It is difficult to estimate the
quantity of annual use of the
chemicals listed above,
because of uncertainties and
lack of information of their
use to automobile parts and
the specific home appliances
in the past.

of ASR which might contain
the chemical listed above is
recycled annually.

of plastics from used specific

Pagina 6

freezer, washing
machine and clothes
dryer) and personal
computers to
constriction material
and daily necessities
such as hangers and
bookends
appliances and establish a sound
material recycle society. Recycling
of such plastics is operated in
environmentally sound manner
under the law.

Recycling used personal computers
is an obligation for personal
computer manufacturers and
importers under the law for the
Promotion of Effective Utilization of
Resources. It is necessary to enable
recycling of plastics from used
computers to maintain appropriate
management system of the used
personal computers and establish a
sound material recycle society.
Recycling of such plastics is
hove appliances which might
contain the chemicals listed
above are recycled annually.

Approximately 5,892 tons of
used personal computers are
collected annually. On
average, the weight of
plastics which might contain
the chemicals listed above is
approximately 15% of total
weight of personal
computers.

EERA Position Paper On Analysing WEEE Plastics - April 2013 - 0

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EERA Secretariat- Address: Pels Rijckenstraat 5, 6814 DK Arnhem, The Netherlands

Tel: +31 26 3702008, E-mail: secretariat@eera-recyclers.com, Website: www.eera-recyclers.com

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