end-of-waste when certain types of scrap metal cease to be waste
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October 2012
Alicia García-FrancoFederación Española de la Recuperación y el Reciclaje
FER
Background
Regulation 333/2011
Exportations
REACH
REACH: Recovered Substances
Penalties for non-compliance
Spanish representative before international,
european and national Organizations
FER
FER, main recycling industry association,defends the interests
of the Spanish recycling sector in different
economic, technical and social fields
Since 1982
Our members
ELV dismantling
Shredders Post-Shredder/Media separationWaste processing
Non-hazardous & hazardous managers. Carriers. Demolition waste managers. etc
WEEE treatment Used Tyres treatment
Our members
FER members
Associationsmember of
FER
FER representsmore than
440 companies
FER members represent 90 % of the scrap recovered in Spain
Associations members of FER
REGIONAL NATIONAL
International Representation
BIR
EUROMETRECSince 1995
EFRSince 1995
Ion Olaeta (FER President)Was Chairman Metal and
Media Separation Committee
Alvaro Rodriguez (FER Board of Directors)
Was Chairman International Environmental Council
End-of-Waste
Background
2002
• Sixth Environment ActionProgramme.
The strategy calls for the development or revision of the legislation on waste, including a clarification of the distinction between waste and non-waste.
Revision of the legislation on waste.
Directive 2008/98/CE of 19 November2008 on waste.
Background
• COURT OF JUSTICE OF THE EUROPEAN UNION
• Mayer Perry Case
• Niselli Case
Background
• a) The substance or object is commonly used for specific purposes;
• b) A market or demand exists for such a substance or object;
• c) The substance or object fulfils the technical requirements for the specific purposes and meets the existing legislation and standards applicable to products; and
• d) The use of the substance or object will not lead to overall adverse environmental or human health impacts.
Directiva 2008/98/CE ARTICLE 6: Certain specified waste shall cease to be waste when it has undergone a recovery, including recycling, operation and complies with:
Background
Article 6.2
End-of-waste specific criteria should be considered, among others, at least for aggregates, paper, glass, METAL, tyres and textiles.
The adoption of the specific criteria and specifying the type of waste to which such criteria shall apply shall be adopted in accordance with the regulatory procedure.
Institute for Prospective Technological Studies(JRC-IPTS)
Background
WORKING GROUP
IPTS
EUROPEAN COMMISSION
MEMBER STATES
NGO
INDUSTRY
AIM: to prepare technical proposals that include all the necessary information and as far as possible makes proposals of end-of-waste for: iron, steel and aluminum scrap, copper, paper, glass in conformity with Article 6 of the WFD.
Background
Recycling sector
National Federation in the EU
EFR(European Ferrous Recovery and Recycling Federation)
EUROMETREC
(European Metal Trade and Recycling Federation )
We were essential to bring the recycling sector point of view
Background
IPTS FINAL REPORTS
Have shown that iron, steel and aluminum scrap comply with Article 6 of the WFD conditions.
Regulation333/2011
Regulation 333/2011
QUALITY
GRADES
STERILES <2%/5%
FERROUS OXIDE
FREE OF VISIBLE OIL
RADIOACTIVITY TEST
NO HAZARDOUS PROPERTIES
NO PRESSURISED OR CLOSED CONTAINERS
INPUT
CONTAINING RECOVERABLE
METAL
HAZARDOUS WASTE
No filings and turnings with
oils
No barrels and containers wichcontain or havecontained oil or
paints
PROCESSES
SEGREGATION
MECHANICAL TREATMENTS
Specificrequirements
for wastecontaininghazardous
components
QUALITY MANAGEMENT
SUITABLE
VERIFIED
( every 3 years)
MONITORING
REQUIREMENTS
STATEMENT OF CONFORMITY
CARACTERISTICS
RADIOACTIVITY
VERIFICATION
STATEMENT
Regulation 333/2011
QUALITY MANAGEMENT– DOCUMENTED PROCEDURES
Acceptance control of waste used as input for the recovery operation;
Monitoring of the treatment processes and techniques;
Monitoring of the quality of scrap metal resulting from the recovery operation;
Effectiveness of the radiation monitoring;
Feedback from customers concerning compliance with scrap metal quality;
Record keeping of the results of monitoring ;
Review and improvement of the quality management system;
Training of staff.
Regulation 333/2011
STATEMENT OF CONFORMITY - ANNEX III
Regulation 333/2011
All the conditions established in Annex I/Annex II are fullfilled
A verified quality management isimplemented
A statement of conformity isissued for each consigment
PRODUCT
If these 3 conditions aren´t fulfilled the scrap can not be a product
Regulation 333/2011
WASTE PRODUCT
WASTE PRODUCT
WASTE PRODUCT
Regulation 333/2011
ALWAYS WASTE
Regulation 333/2011
• This recognizes the processing, cleaning and homogenization work performed by the recycling sector.
MAIN FOCUS ON RECYCLERS
Regulation 333/2011
Explanations
It´s voluntary
It´s applied only to materials processed by a manager.
Not every scrap material will cease to be waste.
A statement of conformity is essential.
Exportations
IRON, STEEL AND ALUMINIUM EXPORTATIONS
WASTE
Regulation 1013/2006 on shipments of waste
PRODUCT
Annex III: Statement of conformity
REACH IMPLICATIONS
Article 2.2 Regulation concerningREACH
• ¿What´s waste? Waste as defined in waste legislation.
• Waste is not a material subjected toRegistration, Evaluation orAuthorisation.
Art 2.2: Waste as defined in Directive 2006/12/EC of the European Parliament and of the Council is not a substance, preparation or article within the meaning of Article 3 of this Regulation.
REACH: Recovered Substances
• In principle, the recoveredsubstances have the sameobligations as original substances,
But
– Shall be exempted from REGISTRATION, DOWNSTREAM USERS and EVALUATION if they fulfill article 2.7.d) conditions
* This exemption applies only to substances recovered in theEuropean Union.
REACH: Recovered Substances
CONDITIONS
REG
ISTR
ATI
ON Substances,
on their own, in mixtures or in articles, have been registered
SAM
ENES
S The substance that results from the recovery process is the same as the substance that has been registered
DA
TA S
HEE
T The information required by Articles 31 or 32
REACH: Recovered Substances
A. THE SAME SUBSTANCE HAS BEEN REGISTERED BEFORE
Aluminium, iron, copper, nickel are already registered: ECHA
web.
There is no requirement that the substance has been registered by an actor in the same supply chain or has any link between the initial and recovery registrar.
Alloys are considered as (special) mixtures and the substances in those mixtures are subject to registration.
REACH: Recovered Substances
A. THE SAME SUBSTANCE HAS BEEN REGISTERED BEFORE
Duty to communicate information down the supply chain for substances for which a safety data sheet is not required (aluminium, steel for example), if available:
Regulation REACH: Article 32.1. a).
ECHA Guidance on waste and recovered substances: Section 2.4.3.
REACH: Recovered Substances
CONDITIONS
REG
ISTR
ATI
ON Substances,
on their own, in mixtures or in articles, have been registered
SAM
ENES
S The substance that results from the recovery process is the same as the substance that has been registered
DA
TA S
HEE
T The information required by Articles 31 or 32
REACH: Recovered Substances
B. SAMENESS OF SUBSTANCE ALREADY REGISTERED
The substance that results from the recovery process has the same chemical identity and properties as the substance that has been registered.
Scrap metal entering processing plants are crushed and shredded for example but are not chemically altered.
The argument must be put forward only if the competent authority explicitly asks the question.
Sameness document for aluminium alloys made by EFR and EUROMETREC.
REACH: Recovered Substances
CONDITIONS
REG
ISTR
ATI
ON Substances,
on their own, in mixtures or in articles, have been registered
SAM
ENES
S The substance that results from the recovery process is the same as the substance that has been registered
DA
TA S
HEE
T The information required by Articles 31 or 32
REACH: Recovered Substances
C. INFORMATION REQUIRED BY ARTICLES 31 OR 32
The legal entity that did the recovery must ensure that information on the registered substance is available to it.No Safety Data Sheet (SDS) required for aluminum or steel other information sufficient.
Safety Information documents foraluminum, steel or stainless steel developed by EFR and EUROMETREC.
REACH: Recovered Substances
REACH: Recovered Substances
Documentationdistributed to FER
members
Penalties for non-compliance
Member States shall lay down the provisions on penalties applicable for infringement of the provisions of this Regulation and shall take all measures necessary to ensure that they are implemented. The penalties provided for must be effective, proportionate and dissuasive.
Next Works for End of Waste Criterias
• GlassAdopted
(Tac 9th July)
• Copper and Alloys (Brassand Bronze)
• Paper
In Progressfor adoption
• TyresIPTS- Work2013
Conclusions - Key Points
It´s voluntary
It´s applied only to materials processed by a manager.
Not every scrap material will cease to be waste.
A statement of conformity is essential.
It is not difficult to comply for our sector.
Until now the smelters will not pay more forproduct/waste, may with time…
It´s a good solution for transboundry trade
THANKS FOR YOUR
ATTENTION
consultas@recuperacion.org
www.recupeacion.org
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