European Waste Classification threatens the circular economy
New European legislation may mean that a large quantity of waste may no longer be used as building material, but must be dumped as hazardous waste.
It is an unnecessary measure and disastrous for the Dutch recycling policy. ECN offers a tried and tested measurement method as a solution.
An important starting point for a circular economy is the reuse of all materials. But that is only possible if the waste to be recycled does not contain hazardous substances. Waste is therefore classified according to European and national rules into ‘hazardous’ or ‘non-hazardous’. The latter category can be reused as secondary building material. One example is raising the ground level when constructing roads with bottom ash from waste incinerators.
The use of waste as a building material is evaluated in the Netherlands in terms of the actual risk for humans and the environment. Limits have been established to restrict the risks to acceptable levels, enabling reuse. In the EU legislation for waste classification (Directive 2008/98/EC), a worst-case evaluation is used, based on the intrinsic danger that a material could pose, without examining the actual risks when applied. “The European Commission’s current proposals for waste classification, especially the hazardous property Ecotoxicity, lead to unnecessarily strict evaluations for a number of waste substances,” says ECN researcher André van Zomeren. “A substance only causes harm to the ecosystem when it is dissolved in water. If you can demonstrate with a leaching test that the substance does not dissolve or only slightly, then it does not pose an unacceptable risk for ecotoxicity, and you can safely use it as secondary building material. Therefore, a risk analysis should be used instead of the worst-case approach of the intrinsic hazardous properties.”
In the Netherlands, this risk analysis has been applied for decades and offers a solution for evaluating the ecotoxicity of waste substances. It is currently not obvious whether this risk analysis is an acceptable procedure for the European Commission because the current proposals for evaluating ecotoxicity are all based on the intrinsic hazardous properties. If the latter evaluation methods are retained, they will have disastrous consequences for the Dutch recycling policy, according to Van Zomeren. A number of waste substances that we now reuse in the construction industry would have to be classified as hazardous waste. That would result in 1.5 million tonnes of additional waste to be dumped in the Netherlands, and we would have to double the landfill capacity in our country.
Van Zomeren argues for clarifying the situation and making it possible for EU member states to determine the evaluation of ecotoxicity themselves on the basis of test methods determining the risk of waste, like the leaching of substances from bottom ash. The other day, ECN presented a report in Brussels that outlined various alternative methods for classifying waste, with an emphasis on determining the risk. “That report was distributed to the member states and led to several countries modifying their opinion about the current proposal,” added Van Zomeren. “Ultimately, we all want to enable the transition to a circular economy, and that is possible even when you evaluate the materials for any risk during application. In that way, you remove the materials that are not suitable for reuse while the acceptable materials are evaluated for their performance when applied. Hopefully, the report and the discussions in Brussels will lead to amendment of the European legislation, so that reuse will not be endangered.”
For more information about our proposed solutions for the circular economy and waste classification, go to our expertise page.