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October 2000

EBFRIP Response to DTI Questions Regarding the European Commission Proposal on Waste Electrical and Electronic Equipment (WEEE)


Answers relevant for Questions 5a and 5b:

Separation of plastics containing brominated flame retardants would represent a tremendous logistical and financial challenge to recyclers and would for certain recovery and recycling processes result in the imposition of additional unnecessary costs.

Infra-red technology for separating out different plastics and their different additives (including flame retardants) is in the course of development. The availability of such technology is hardly guaranteed. Brominated flame retardants are often used in small plastics parts and cables. TBBPA is the major flame retardant for printed circuit boards, accounting for 96% of the market. In view of the small size of these components it would be technically impossible to separate out plastics containing brominated flame retardants as is proposed. In short, mandatory specification of the separation of all plastics containing brominated flame retardants risks being costly and difficult, if not impossible, to implement.

Separation of all plastics containing brominated flame retardants would create two waste streams for WEEE plastics neither of which in themselves are technically viable for recycling. Mechanical recycling can only be carried out on a polymer per polymer basis. The separation requirement therefore makes no sense from a recycling point of view.

Separation of large plastics part by individual polymer makes sense when there is a market for recycled WEEE plastics. It should be left to the recycler to determine for what material he has a market and when. Specifying the separation of different materials in an EU Directive will merely lead to separation of materials for incineration or disposal.

The separation requirement also ignores the fact that the major process for recycling WEEE metals does not require the separation of materials prior to the recycling process. A few individual metal smelters in Belgium, Germany and Sweden are equipped to recycle the metals from WEEE, which is often made up of metal and plastics parts which are for all practical purposes to separate in view of their minute size. Tests in these smelters demonstrate full compliance with regulatory limits for environmental and worker safety. Enforcing separation of all plastics containing brominated flame retardants would introduce unnecessary costs for these important recycling processes.

In calling for all plastics containing brominated flame retardants to be separated out, it could be inferred that these materials are particularly problematic for recycling. In fact certain plastics/brominated flame retardant combinations are actually specified by leading manufacturers of photocopiers in part because of their very good recyclability in closed loop processes. The inclusion of plastics containing brominated flame retardants represents an unjustified stigma against these materials.