Document G6ykQ2o6XN060GMO7VMDZ7Kmr

Society of The Plastics Industry, Inc. Robert H. Burnett Executive Director August 26, 1993 TO: VIGOR RE: European Biannual Report Attached for your review and internal use is the mid-year report on European environmental developments prepared by Rolf Buhl of EVC. Based on the individual country summaries, it would appear the status of PVC has improved since the last report. As usual, please respect the "note" on the cover page. Sincerely yours RHB/pmb cc: Executive Board Issues Management Committee P. de la Cruz CTL006607 Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299 Fax if (201) 890-7029 >;.; -^pf-x.'i T*^^5 * ' ' - "*'`l" S yi`:?:-\ '-' ?? a~JS^X*V-~;Xr:-:'- - ir<?a ISvtf* i :$Sv& >V ,*i .'s^>?0'*^A/,*. ''* "iatS- ? S* -'*-S 1 --v^rOX^Sf*Cx -1 ~J -XV;V m *i^.>r`r;rV-':- ** ;va`S s^.r;;-'.-^ >?:.- s~,c'o'a: >vv. '' .yr'-'lC -^v; X.'^C<S>**V<f.`S* ?r>*.-`.vH>J_^3r,'-S\^'i--^,.7-*;"T-V';-'st'<*'.- -.V ` fA!,':-i^"ik* '''i&'"'-it. -g&S. }~&-%'^-.T?.--; s&yt: fr^;r KJgiSS^1' CTL006608 __ _^^s&>4aKIHSti European Vinyls Corporation International SA/NV B-1160 Eruxelles Belgium Tel. (02) 674 09 11 Telex 24 200 EVCB Telefax (02) 660 11 81 From : R Buhl To : See circulation list CcSCftAS v nu$ CO=?ORATOn 9 August 1993 UPDATE OF THE PVC RELATED ENVIRONMENTAL DEVELOPMENTS IN EUROPE AS PER JULY 1993 Note : This periodical update has been put together for our employees, customers and selected members of the industry. It covers the current, but constantly "moving" environmental debates in Europe concerning PVC to encourage an exchange of information. Tomorrow some major developments may have changed in one or the other direction. Therefore, this and other updates on environmental developments should only be seen as a "spotlight" that needs regular adjustments to present the trends. We do not recommend that any part of this note is quoted out of context or distributed separately, since this could lead to misunderstandings. Last "update" : January 1993 TVA BE 429.158.682 RC. B 482 997 CTL006609 CONTENT 1. Austria 2. Belgium 3. Denmark 4. France 5. Germany 6. Holland 7. Italy 8. Luxemburg 9. Norway 10. Spain 11. Sweden 12. Switzerland 13. UK 14. Developments at EC level 15. Other European Developments Appendices 1 to 8 Page 1 2 2 3 3 5 6 6 7 7 7 8 9 9 10 CTL006610 1. AUSTRIA The PVC debate at governmental level is quiet. The new Environmental Minister has stated that this is not the time to regulate against PVC "though the use of PVC for short life products needs some review". A draft ordinance to restrict the usage of Cadmium in products to below 0,01% circulates amongst industry. There are a number of exceptions, but the key positive exception concerning PVC is for "recyclate when not Cd poststabilised". Attempts by the Greens continue to exclude PVC from public purchase programmes. Whilst the Land of Tirol voted against such a motion, the Land of Niederosterreich intends to take measures against short and longlife PVC products. API is already in correspondence with the Nieder-Osterreich authorities and the other Lander to counter this development. As a response to a number of media reports on "PVC is a dead product and industry is cutting back investment programmes", API countered with a well attended press conference, covering presentations from ECVM and EVC. The PVC advertising campaign as organised by API continues. Emphasis is put on the social benefits of selected products such as pharmablister, pipes or window profiles. New within this campaign are billboards with the same message, located at traffic centres. Expert hearings as part of the industry court case against the Greenpeace campaign "Stop PVC - Environmental Poison" are completed since the last court meeting in May. Both parties are now waiting with great interest for the final judge ruling, promised for August this year. Reeve!ing : Work is progressing towards establishing the nationwide collection and recycling system for used packaging, called "Altstoff Recycling Austria (ARA)". Like DSD in Germany and Eco-Emballage in France, it will collect fees from manufacturers and-distributors and channel the money to collection and recycling organisations. It hopes to have the necessary infrastructure in place to begin operations by 1 October 1993, when the Austrian Packaging Ordinance comes into Force. The plastics interests are looked after by OKK - CTL006611 2 "Osterreischer Kunststoff Kreislauf" (For recovery targets see previous report). 2. BELGIUM Top media attention is still on the ecotax bill. It has passed the Parliament in June and is now before the Senate for final approval. An expert commission has been set up to study the economical and ecological effects the ecotax will have when PVC mineral water bottles are exclusively taxed with BF 15 with no exceptions for recycling. This report has to be published before year end and will form the basis for a second vote by the Parliament. But while there is still debate on the ecotax bill, the packaging industry has come forward with a recovery scheme called "Fost Plus". It favours the free-market concept of the "green dot" as applied by the Duale System in Germany or Eco-Emballage in France, and with targets to meet the EC Directive on Packaging and Packaging Waste. A Belgian court has fined Greenpeace following a demonstration in March in which activists managed to block transport into and out of a Solvay plant in Antwerp. When the protestors refused to leave the plant, the authorities were called in to remove them, and an injunction awarded to Solvay to prevent further trespassing. In addition, Greenpeace have been ordered to pay for the disruption caused to the company's business. In order to secure payment by Greenpeace of penalties and damages due to Solvay, a court order was obtained in April freezing Greenpeace's bank accounts in Belgium ! Recvcling PVC bottle collection and recycling continues. This is being organised by Revipack, a joint venture between Solvay and the French mineraliers, but open to other PVC producers, too, to share the costs. 3. DENMARK Except for the usual Greenpeace attacks, the PVC debate is quiet and there is no news from the Environmental Ministry. NKT, the local PVC cable producer, has introduced a CaZn stabilised cable as a response to the "voluntary agreement" between industry and government to phase out heavy metal stabiliser. This step is getting wide attention within the PVC industry - not just in Denmark - and forces other cable manufacturers to make up their minds about the future of lead stabilised cables. This subject was also on the agenda of the recent environmental meeting in Copenhagen between the European cable producer association (Europacable) and ECVM. No collective decision was taken, but the industry position will be reviewed at the next meeting in autumn. CTL006612 7 Recycling Initiatives are underway to establish recycling schemes for PVC pipes and window profiles, again as a response to the before mentioned "voluntary agreement". 4. FRANCE Quiet regarding PVC. The plastics industry concentrates on the packaging waste decree through Eco-Emballage, and Valorplast in particular. Separate draft proposals on automotive waste have been put forward by the Environmental and the Industry Ministry. Key element is the limitation of "non-valorised parts". Whilst the Environmental Ministry wants to have this limited to 15% by 1994 already, the Industry Ministry argues for 15% by 2002 and for 5% by 2010. Once again (and typical for the French policy ?) there is no hierarchy to the recovery ("valorisation") options. Reeve!ing No further news. 5. GERMANY The excitement at year end 1992 on th "TA- Siedlungsabfall" with its discriminatory paragraph on PVC settled down when the Bundesrat in February adopted the corrected text with no specific mention of PVC. In February too, the PVC industry met officials of the BLAU committee (= 16 federal environmental ministries) to present their position opposite the various recommendations of the BLAU report on the environmental impact of PVC. BLAU will return in October/November 1993, most likely with a request for "voluntary arrangements" on heavy metals (Cd and Pb substitution), R-VCM limitation in the polymer and a comprehensive waste management scheme. As requested by the Parliament, the "Enquete Commission" called for a hearing on "Chlorine and PVC issues". With regard to PVC the emphasis was on the waste treatment of PVC longlife products such as windows, pipe, cable and flooring. AG-PU and VKE (PVC group) both presented the PVC industry position. The hearing concluded with no particular PVC discrimination. In fact, Greenpeace and BUND already criticised the Commission "by being too soft to industry"! But TA Siedlungsabfall, BLAU and the Enquete Commission (and the many other attempts to discriminate PVC) all contain one common element : PVC waste treatment creates an extra (cost) burden to the public, and as long as there is no solution/acceptance, the deselection process will continue. CTL006613 4 This was once again demonstrated by the recommendation of the Hessia Parliament to not purchase PVC products for their public building programmes ("Forderverbot fur PVC im Wohnungsbau"). Initiated by AG-PU and lead by the industry union "IG Chemie" some 6000 employees of the PVC industry demonstrated in front of the Hessia Parliament (Government : coalition of socialists and greens !) against this discriminatory act. (In this context see also in Appendix 1 the request of Hermann Rappe, MdB and President of the IG Chemie, to all MP's to stop the anti-PVC debate). A group of MP's were taken around to PVC plants, convertor and recycling operations. On 22.7 the Hessian Parliament withdrew its "anti-PVC recommendation" but specified the purchase of public PVC building products such as pipes, windows and flooring to contain 70% recyclate. Whilst the withdrawal from the original "Forderverbot" is a positive development, the high recyclate content will cause big problems to achieve because there will not be enough recyclate available from these longlife applications ! It is for all these reasons, why the PVC industry in Germany (producer and convertor) is working on a comprehensive PVC recovery scheme, called "Kreislauf Konzept" (closed loop scheme) with top priority to change the anti-PVC trend. For more details on this subject see subtitle "Recycling". What started last year with the Lengerich fire in a recycling plant, continued this year with a series of fires in other plants, some involving PVC. With so many incidents occuring, it is too much to believe that these were just accidents. Criminal intent must be suspected ! Industry had an expert group in place to follow up any of such fires. A report on the findings has been put together by AG-PU. In contrast to the widely-held belief, that these fires involving PVC - even at large quantities - are a major dioxin source, the conclusions from this report read : * In the immediate vicinity of major fires involving PVC, no or only slightly increase dioxin and furan pollution is to be found. * The residue of major fires involving PVC contains dioxin and furan pollution which is closely associated with soot, and which can be removed through observance of the guidelines issued by the Federal. Public Health Department. * Investigations into fire fighting personnel have revealed that, in comparison with other people, such people do not display increased levels of dioxin contamination. Reeve!ino The "Duale System" for the recycling of packaging waste has come to a "quasi-collapse" in June when 400 ktons of collected plastic packaging met a recycling demand of only 150 ktons and ran short of capital (500 Hill DM loss). The 150 ktons are well above the 9% CTL006614 5 recycling target for 1993 (approximately 90 ktons), but the out of balance collection resulted in huge mountains of sorted plastics without recycling facilities. Many experts expected this failure, but probably not so early. At present the industry, together with Minister Topfer is searching with top priority for a solution. A new company, DKR (Deutsche Kunststoff Recycling GmbH) will be formed to combine the interests of waste collection and recycling. It will replace VGK, who represented so far the interests of the plastics industry. 100 Mill. DM are still needed to get DKR and the recycling of plastic packaging going. But before rushing into DKR and entering the next pre-determined disaster, the plastics industry is advised to negotiate concessions to the original Topfer ordinance with access to incineration (Appendix 2). Much of the industry's activities now concentrate on feedstock recycling. Favoured in Germany is the hydrogenation process as operated by Veba Oil in Bottrop. Already in September this year this plant will be ready to take 20 ktons p.a. of mixed plastics packaging waste including some PVC (current PVC share in DSD collected plastic waste is 5 to 6%). This will grow to 40 ktons p.a. in 1994. Thermal cracking and dehalogenation are essential pre-treatment steps for the feedstock recycling of mixed plastics including PVC. Connected to this development are already the first requests that PVC has to pay for the extra "dehalogenation costs". Against this background and what has been reported further up, the "Kreislauf-Konzept" for the treatment of PVC waste products under the management of the PVC industry is gaining support amongst member companies. The recovery of HC1 (and energy) from a central, but purpose build incinerator, feeding a nearby oxychlorination plant, is a key element of this scheme to treat the large quantities of PVC waste products (Appendix 3). But there are still a number of important issues to be solved (i.e. total cost and how to finance a voluntary scheme, HC1 vs. chlorine capacities, logistics, etc.) as phase I = the acceptance study ("Allensbach Studie") on the "Kreislauf-Konzept" revealed. The PVC industry within AG-PU is now entering with Phase II a more detailed feasibility study, to be finished in spring 1994. This is still a long process for all those who wish to see a quick change in the anti-PVC and deselection process, but to expect something shorter underestimates the complexity behind the whole issue and bears the risk of failure (see Duales System !). 6. HOLLAND The debate on PVC between industry and the authorities reached another level when the Board of Appeals of .the Dutch Foundation for Publicity Codes confirmed a previous judgement (verdict of June 4th, 1993), that the Dutch Ministry for Environmental Control (VR0M) was unable to demonstrate that PVC should be avoided for environmental reasons and that any publications in this respect are misleading and as such undesirable. This verdict should put an end CTL006615 6 to the discrimination statements and publications from VROM officials (for more details see full text of the BFK press release, Appendix 4). In a regulation on wine packaging an attempt was made to exclude PVC as a packaging material as from January 1996. Following protests by the British industry, the European Commission informed the Dutch government that they are in breach of Article 30 of the Treaty of Rome. Consequently, the Dutch have postponed adoption of this wine packaging ordinance. Recycling No further news. 7. ITALY The PVC Working Group within Assoplast is in regular contact with the authorities and was able to prevent any legislative discrimination of PVC. A conference on the environmental aspects of PVC packaging was organised by the Trieste University, with sponsorship from EVC and Solvay. It brought together the leading authorities, packers, processors and expert toxicologists in this field. Media reports have been very positive about this event and encouraged Assoplast to put the findings together in a brochure for wider distribution. It will contain conference statements like * "Mineral water in PVC bottles is as safe and hygienic as bottled in glass" (Prof. Maltoni, Toxicologist from Bologna University) * "Collected PVC bottles are recycled" (G.R. Prati, Director of Replastic) * "There is no reason to ban PVC as a packaging material" (M.P. Garavaglia, Minister of Health) * "We are against overpackaging but not against PVC packaging" (Lega Ambiente, consumer protection group) Such positive media reports forced Greenpeace to take immediate action. The EVC HQ offices in Venice were occupied a few days later until police cleared the site. The occasion was used by Greenpeace to catch media attention through its report "PVC : Dioxin Factories", but failed. (For more details on this report see chapter 15). 8. LUXEMBURG Nothing new to report. CTL006616 7 9. NORWAY To respond to the request from the Norwegian Environmental Ministry to phase out PVC packaging, the Coordinating Council for Packaging and the Environment (SEM) was asked to prepare a position document. The SEM report has been published and handed to the Ministry. In its conclusions it reads : "PVC can be replaced in some areas, but there are also certain critical areas in which this is not possible. A phasing out of PVC would, however, require relatively expensive financial measures by industry. The environmental savings would be limited. The ecotoxicological effects have not been considered, either for PVC or for alternatives. The analysis does not provide any grounds for imposing the phasing out of PVC in packaging. Parts of the analysis clearly indicate that PVC on the whole is a better alternative environmentally than its possible replacements." For more details see the translation (Appendix 5) of the SEM covering letter to the Minister. The Minister in turn made a preliminary statement to the press "that as far as he could see, the criticism against PVC appeared to be rather exaggerated." He also instructed the Environmental Protection Agency (EPA) to conduct a survey on the environmental impact of PVC building products, with a report by the end of 1993. There should be no more negative official statements in the meantime. However, the "ripple-effect" from other countries, namely Sweden and Germany, should not be underestimated. Recycling Nothing new to report. 10.SPAIN Nothing new to report. 11.SWEDEN In May the Swedish Parliament adopted an "eco-cycle ordinance", introducing the legal principle of "producer responsibility". The policy behind it is similar to what Minister Toepfer in Germany tries to establish with his proposed "Kreislauf Gesetz" and means, that even when a product has ceased to serve its original purpose and has become waste, the producer or importer is responsible for dealing with it "in an environmentally-friendly manner". An Ecocycle Commission has been set up to establish the principles. One of the tasks given is to draw up a plan for the phasing out of PVC shortlife products, namely PVC packaging, another one will have to deal with the restriction of all chlorine containing products. The PVC industry, lead by Norsk Hydro, is making every effort to . CTL006617 make its position known and to request official ecobalance assessments prior to any phase out decisions. Much to the surprise of the PVC industry all over Europe, and without any pre-warning, Lars Wisen, MD of Tarkett-Pegulan, gave a press conference in June with the message, "that they are taking steps to move away from PVC as a flooring material in all their plants, and will replace it by a chlorine-free alternative". This move is claimed as "a give-in to the pressures from the Greens, who call PVC an environmental product". One can react to this move in many ways, but if something went wrong and should be criticised it is the timing and style of the announcement. Industry is responding at top level contact. However, the announcement is out and much effort will be needed to limit the damage ! Reeve!ing Nothing new to report. 12.SWITZERLAND To lift the legal ban on PVC beverage containers is still not given up and subject of meetings taking place between the Commission (DGI, DG III and DG XI) and Swiss officials, with input from industry. Much of the progress now depends on the Swiss PET recycling industry to tolerate PVC as a 2nd bottle polymer by using advanced separation technologies as done in other countries, and eventually on the political will to verify the law. The deselection attacks on PVC building products continue at canton level, backed by a Greenpeace campaign on this application sector. Similar to the developments in Germany (read "Hessia") the environmental departments are coming forward with "guidelines for the environmentally-friendly building" (Leitfaden fur okologisch orientiertes Bauen) which place PVC building products into the "avoidance category" without assessment of the alternatives. Legal steps are being considered to counter the publication of these guidelines, and a visiting programme initiated to directly reach the authorities behind it. Also, the Swiss PVC Group tried to organise a face to face meeting with Greenpeace and other pressure groups on "PVC in buildings", but all opponents refused participation. An advert was then placed by the PVC Group in the daily newspapers, claiming that the pressure groups attacking refuse dialogue and fact finding. Recycling Schemes are being set up to collect and recycle credit cards and office material. CTL006618 13.UK The pace to come forward with a national waste management scheme is speeding up and the DOE (Depart of Environment) already declared, that it will introduce mandatory measures if a voluntary funding scheme as proposed by COPAC is not established quickly. Target is still 25% of household waste (primarily used packaging) to be recycled by the end of this decade, with the French Eco-Embal1 age, but not the German Duale System, being the preferred model. Within this regulatory debate there is much talk about "industry responsibility" and "producers to bear any extra costs to meet the targets", without being specific. The plastics industry must speak with one voice only opposite the Government and the other parties involved. The BPF is aware of this and consequently is restructuring its organisation. Within BPF there will be a "PVC focus group" to cover the PVC industry interests. Waste management and other environmental targets will have top priority on the agenda when the group starts its work after the summer holidays. Greenpeace is stepping up with its "anti-chlorine and PVC campaign" too. Its recent activities are targetted towards architects, builders and town councils warning about the fire hazards (HC1, dioxin) of PVC building products. Much of the Greenpeace arguments are "imported" from Germany and Austria, raising great concern amongst our UK customers. Following a series of visits for Ford - Germany and Ford - US, a PVC industry group met a joint Ford-US/Ford-UK delegation at the Dunton HQ to discuss PVC issues. Behind is the need to reposition PVC in Ford's worldwide material policy and to avoid any discrimination or deselection process. Recycling of PVC automotive components is a major request from Ford and the industry has still to come forward with convincing solutions. Recvclino IBM, Hydro, Goodrich and The Mann Organisation have announced to jointly establish a collection and recycling scheme for used PVC computer components such as keyboards. Initial experience has shown that the recyclate can be moulded back into new IBM keyboards. It is the first of this type in Europe, if not worldwide. 14.DEVELOPMENTS AT EC LEVEL The draft directive on packaging and packaging waste is entering a new phase. The Vertemati report on the Commission's proposal was adopted by the "Environment Committee of European Parliament" on June 2nd. Some 130 amendments were added when this document reached the European Parliament for its first reading on June 21 23. Problematic for PVC was an amendment as introduced by Denmark requesting : CTL006619 TU " a prohibition of packaging containing halogenated or chlorinated components 10 years after adoption of the directive" " Limitation of heavy metals in the packaging material, for Zn < 400 ppm, within 5 years after adoption of the directive". In its vote on June 23 the European Parliament refused the prohibition request for halogenated or chlorinated compounds but adopted a text which reads : " Intermediate targets shall be established for the gradual reduction of packaging materials containing halogenated or chlorinated components". With regard to the Zn-1imitation, this part of the amendment passed the parliamentary vote. It should be noted here, that the European Parliament has no legal power, and its voting has only "advice character". The PVC industry made its concerns known to the Commission via APME (Nancy Russotto) and called for a neutralisation of these restrictions. It should be noted here, that such restrictions are unlikely to pass the Commission, because they contradict with its own position to not discriminate against single products if there is no environmental reason to do so. The Commission is currently redrafting the text of the proposed directive and prepares for a 2nd reading in the Parliament, scheduled for September/October. In between close contacts with key MEP's will continue. (For more details on the APME position on recycling targets and PVC see Appendix 6). More generally, the EC is reviewing its policy on priority waste steams. In addition to the packaging waste directive it will concentrate effort on * used types * chlorinated solvents * end of life vehicles * health care waste but will postpone work on "demolition (building) waste" and "electric/electronic waste". This sounds initially as good news, but member states remain free to develop their own programmes do not infringe EC law, particularly free trade rules. 15.QTHFR FUROPEAN DEVELOPMENTS At the end of April Greenpeace issued a report, claiming that VCM/PVC plants are huge dioxin sources. Press conferences were held all over Europe to make this report known (Appendix 7), but with a few exceptions the media attention was low. A response document has been prepared by an expert group within ECVM. A copy can be ordered from ECVM or R. Buhl office. It was CTL006620 TT made available to the press, too, with a covering statement as shown in Appendix 8. R Buhl (with input from ECVM and the EVC Environmental Committee) August 9, 1993 Enclosures : Appendices 1 to 8 C1L006621 Htrai.t;egefcen vor. tv PrssMtblellurg tv Irdtrir'^jewerkichaft Cf**r>!-Picer*'<e,ar'.ik, HaipHorsUnd, Kir.igrv-orJ'.K Plan 4, 3CT.67 Hannover Veftr.twoclich: Bamd LalWned T*lrfon:(C5n)76 31-3 24 u. 3 29 Telefax; (OS 11) 7 00 08 SI remtchreibec. 09 22 603 igche d jH IG Chemie Si* Papier V Keramik Rappe: PVC-Verbot unserios Steckt hlnter dem PVC-Verbot der Einstieg In den Ausstieg aus der Chlorchemie? Vor einor gedankenlosen Ubertragung des hessischen PVC-Verbotes auf endere 3undeslander hat der Voraitzende der IG Chsmie-Papier-Keramik, Hermann Rappe (MdB) am Montag (12.7.) in Bonn gewamt Stattdesaen musse die Wienbadener Landesregierung ohne Rucksichtnahme auf koalrtionstaktische Spielchen das PVC-Verbot im offentlichen Bauwe&an nhiw wnn imH aber zurucknehmen. Das erklarte der IG-Chemie-Voraitzende bei einem Gesprach mit Betrtebsraten aus der hessischen PVC-Industrie. Der LandtagsbeschluB sei noch zu Zeiten einer CDU/FDP-gefuhrten Landesregierung gefaSt v/orden. Er sei ohne Beieiligung der betroffenen Arbeitnehmer und ihrer Gewerkschaft zustande gekommen. Rappe wamte vor den Oberlegungen andererBundeslander, dem hessischen Beispiel zu folgen: -Ein pauschales PVCVerbot iot nicht allein arbeitsmarktpolitisch, sondern auch umweitpolitisch unverstSndlich." Viele der vorceschlagenen Ersat2stoffe wSren nicht selten selber riskant fur Gesundheit und Umwelt und zudem oft noch leurer Es ist nicht serios, Ersatzstoffe fur PVC vorzuschlagen, die ungleich grbBere dkologische, gesundheitliche und nicht zuletzt auch wirtschaftliche Probleme aufwerfen.- Der IG-Chemie-Vorsitzende warnte davor, daB bei einem undifferenzierten Verbot die Industrie Yon ihrer freiv/illigen Verpflichtung zur PVC-Rucknahme zurOcktreten konnte: Ein PVC-Ausstieg bedeutet, daB die Wiedervervvertung durch Recycling gefahrdet ist und damit eine vemunftige Kreislaufwirtschaft verhindert wird. Er gehe davcn aus, daB es bei der gegenwSrtigen Auseinandersetzung nur vordergriindig um die PVC-Baustoffe geht: In Wirklichkeit wollen die Grunen gezielt den planmSBigen Ausstieg aus der Chlorchemie vorantreiben. Da 60 Prozent der gesamten chemischen Industrie mit dem Rohstoff Chlor zusammenhange, habe das katastrophale Folgen fur die gesamte Branche: Wer uber ein PVC-Verbot gezielt den Ausstieg aus der Chlorchemie vorbereitet, gefahrdet 300000 Arbeitspiatze in der Bundesrepublik und einen lebenswichtigen Industriezweig mit 100 Milliarden DM Um$atz. Rappe appeilierte an die "Arbeitnehmerpartei SPD, nicht aus kunrfristigen wahloder koalitionstaktischen Grunden vor einer klaren Aussage zum Thema PVC und Chlorchemie zu kneifen: *Wer um einer grunen Klientel zu gefallen, lieber schweigt, muB sich nicht wundem, wenn unter den Arbeitnehmern Politikverdrossenheit entsteht. XXIX/45 12.7.1993 CTL006622 GERMANY IS STARTING TO BECOME REALISTIC Dr. VAHRENHOLT, Senator for Environment, Hamburg "..... doubts that recycling of dirty yogurt cups or similar waste makes sens for the environment". Freie und Hansestadt Hamburg, Press Release, 7 May, 1993. "Ecologists also know that modern waste incinerators can be considered as depollution rather than polluting plants". Dr.Vahrenholt, Senator for Environment, Hamburg, in Der Spiegel - 25/1993, page 50 PROFESSOR VON LERSNER President of the German BUNDESUMWELTAMT " We need in Germany SO to 75 new incinerators for household waste " (Dai inn2) PROFESSOR SCHMITT-TEGGE Director of the waste* dMsfon of the German BUNDESUMWELTAMT " The refusal to accept waste incinerators in Germany is ridiculous " JO LE1NEW - Member of 'die Grunen* party Direction and Minister of the environment of the Saarland' " The incineration of waste is a reponsible and proven method " (H*Wsf>b<( snvw CTL006623 PV RECYC'fLfIlNG concep. CTL006624 Nederlandse Federatie voor Kunststoffen Persbericht June 25ih. 1993 The Foundation for Dutch Publicity Codes confirms that negative publications on PVC are misleading PVC PLASTICS WIN ANOTHER ROUND The Board of Appeals of the Dutch Foundation for Publicity ; Codes has confirmed the previous judgement of the Publicity | Code Commision (verdict of June 4th, '93) that the Dutch ; Ministry for Environmental Control (VROM) was unable to demonstrate that plastic PVC should be avoided for environmental reasons. For this reason the Board considers any publications in this respect misleading and as such undesirable. The Foundation for Code of Publicity came to this verdict as a result of a complaint of the Dutch Plastics Federation (NFK) concerning a brochure published by the Dutch Environmental Ministry. In this brochure negative statements concerning PVC products in office environments were published. i The Board of Appeals came to the conclusion that VROM had not been able to present evidence that incentives to avoid the use of PVC are justified. During the session of the Board all environmental aspects of PVC were discussed in detail. The arguments of VROM for a policy of promoting avoidance of PVC, were all refuted by the substantial evidence of the NFK. The Board of Appeals was convinced by the factual and objective information, -derived from diverse studies- concerning the environmental aspects of PVC, including emissions during production, further processing and waste disposal. " Comparative studies on the environmental.effects of products (ecobalances) also demonstrate that PVC does not yield to other plastics on environmental grounds and often scores better than traditional materials. -vv- Poslbus 420. 2260 AK I CTL006625 1 .rn:i v.'t-i.it % Vi V '"'VC : ~ :-! V1.' V O ~ SAMARBEIDSRADET FOR EMBALLASJE OG MILJ0 (SEM) (The Co-ordinating Council for Packaging and the Environm^-" Mr. Thorbjorn Berntsen Secretary of State for the Environment Ministry of the Environment P.O.Box 8013, Dep. 0020 OSLO 15 January 1993 O-1419/0U3/HLa Disposable packaging containing PVC and PVDC in Norway Enclosed please find 4 copies of SEM's report entitled: "Disposable packaging containing PVC and PVDC in Norway". It can only be justifiable to impose phasing out of a material if it can be established that the environmental advantage gained is in reasonable proportion to any practical or economic disadvantages entailed. With regard to PVC in disposable packaging, our analysis shows that there are some areas where PVC can replaced, but there are also certain critical areas in which this is not possible. A phasing out of PVC would, however, require relatively extensive financial measures by industry. The environmental savings would be limited. The ecotoxicological effects have not been considered, either for PVC or the alternatives. SEM's analysis thus does not provide any grounds for imposing the phasing out of PVC in disposable packaging. Parts of the analysis clearly indicate that PVC on the whole is a better alternative environmentally than its possible replacements. The recommendation of SEM project group and SEM is therefore that the Norwegian authorities should not introduce restrictions on the use of PVC in disposable packaging unilaterally, but should allow the market, in an international perspective, to decide what packaging should be chosen. CTL006626 Teles tsenter/0863rsu End of discussion on PVC ? Previously ihe Dutch Environmental Ministry had already informed the plastics industry to have no formal objections against recyclable PVC products. The judgement of the Foundation for Publicity Codes illustrates that the Ministry has also no substantial arguments to discrimitate non-recyclable PVC products. The Board of Appeals only made a reservation for packaging. This because of the Packaging Convenant from 1991, with which the industry made voluntary agreements to reduce the use of PVC in packaging applications. This agreement was based on the assumed relation between PVC and the formation of dioxines during combustion of municipal waste. Since following research has demonstrated that PVC has no effect on dioxins with municipal waste combustion and ecobalance studies show PVC to be a very good product also for packaging, the NFK considers the voluntary agreement to reduce PVC in packaging to be out of date.The policy of the plastics industry is aimed at revising the Packaging Convenant in this respect. Emotions Mr. W. Beerman, chairman of the Dutch Steering Committee for PVC & Environment, is very satisfied with the judgement of the Foundation for Publicity Codes. " This verdict means the end of a long dispute on the use of PVC in a large number of applications as piping systems, window frames, office appliances, home decorations and many others. With this decision, the Board of Appeals has given a sound judgement concerning PVC at the highest level. All environmental aspects of the PVC substance chain are covered by this. We hope this will contribute to a finishing of the environmental discussion on PVC, which has now been proven to have mere emotional grounds." PVC live cycle management A large number of companies in the Netherlands are active with the production of PVC raw materials and the conversion to end products. Thogether these companies published in 1991 a first report on the life cycle management of PVC. This report not only illustrates the environmental aspects in the cycle, but also presents all initiatives for further improvement of the environmental impact and recycling of PVC products from waste. The decision of the Board of Appeals means an incentive for the conu'nuation of activities with PVC life cycle management. Proper publicity, within the frame of formal product policy, is an important requirement for this. CTL006627 The Norwegian Society for the Conservation of Nature (NNV) agrees with the main conclusion of the report within the limits of the premises on which it is based, but points out that environmental hazards and ecotoxicological effects have not been included in the LCA analysis. On its own initiative, NNV has prepared a memorandum with the title "PVC v products, environmental hazards and reduction of hazards" dated 12.1.1993. This memorandum has not been discussed by SEM's PVC group or board, but is forwarded together with SEM's report. We would like to present the report formally and would ask for an appointment to do so. Yours faithfully SamarbeidsrSdet for emballasje og miljo Kjell H. Vestberg Chairman (sig.) 0istein Lekkeberg Project Manager (sig.) Iekstsenter/0fl63rsu CTL006628 8 4.2. Recycling targets Background The Commission proposal for a Directive on Packaging and Packaging Waste contains a recycling target of 60% by weight of each material to be met 10 years from the date when the Directive is implemented in national law. APME Position Recycling is a key recovery option for the plastics industry. There is an optimum level of recycling which ensures net environmental gain and which should be determined by eco-balance analysis. Many types of plastics exist in different applications. Different applications call for different recovery options to maximise net environmental gain. APME does not support the current Commission proposal for recycling targets for the following reasons: recycling is not the best option for recovering all plastics packaging waste from an environmental point of view; it discriminates unfairly against plastics by setting the same targets for materials which are not equivalent and are not used in the same market sectors (ie glass and metal are used only in the rigid containers market). APME's bottle recycling scheme will enhance the recycling of plastics in these applications however the same targets cannot be met by post-consumer films; it will strongly encourage a swing away from the use of plastics packaging, a move not justified on health, safety, environmental or economic grounds; it will redirect investment away from the infrastructure best suited to the recovery of plastics packaging waste towards a pattern of investment which follows the recovery options favoured by the targets in the Commission text; Evolution The Environment Committee of the European Parliament will be voting on the draft report on the Commission proposal by Luigi VERTEMATI MEP (Italian, Socialist) in June 1993. Both Mr VERTEMATI and Mr BOWE MEP (the Socialist Group Co-ordinator on Waste Management) are tabling amendments which will create conditions whereby certain categories of packaging waste will not have to meet the 60% recycling target. One suggested amendment would exempt from the scope of the Directive packaging smaller than 100cm3 and 3g; another proposal would allow energy recovery of such packaging to count towards fulfilling the 60% recycling requirement. APME is actively working to gather support for such an evolution. CTL006629 Opposing views Members of the Green Group in the European Parliament believe that the recycling targets are not stringent enough. 9 APME Member action To support modification of the recycling target. If the EuroDean Parliament amendments creating exemptions for certain categories of waste are adopted by the Environment Committee, the European Parliament as a whole and the Commission, then these amendments should be promoted to the.Member State Governments as consistent with EC thinking. 4.3. Feedstock recycling Background Within the framework of the EC's proposed Directive on Packaging and Packaging Waste, feedstock recycling has been given a low profile in APME's public affairs campaign. However, several factors are now making it imperative that APME and its member companies address a common strategy. APME Position The main objectives of the APME feedstock strategy can be summarised as follows: to ensure that feedstock recycling is not explicitly excluded from the recycling definition in the packaging directive on the grounds that it is energy recovery. Under its definition in the packaging directive, recycling should result in a "marketable product". By "unzipping molecules", feedstock recycling produces, at the very least, a product which, depending on the waste input and the technology used, is suitable for use to manufacture plastic materials and other chemical products. Furthermore, if this relatively new initiative in feedstock recycling is stifled by withdrawing its value as a recycling solution, future initiatives will be discouraged; to ensure that promoting the technology does not detract from the industry's key aim of reducing the recycling targets in the packaging directive. A common industry policy needs to be communicated which promotes the positive aspects of the technology without suggesting that it will make the proposed recycling targets possible. Feedstock needs to be positioned as an example of the industry's efforts to find solutions, rather than as a solution in itself. Opposing views Feedstock recycling has become the focus of a high-profile environmental debate in Germany. Certain Lander are claiming that feedstock is not recycling but energy recovery and are refusing to recognise feedstock as contributing to the recycling CTL006630 r taraets of the Topfer Decree. APME is attempting to gain EC / 'w' Commission support for recognising feedstock recycling as a valid contribution to recycling targets. APM3 Member action APME and member companies should use the arguments featured above to explain to national government contacts feedstock recycling and its context within the waste management debate. It is important to stress the developmental stage of the technology, pointing out the significant financial costs involved and the limited number of operations currently implementing the technologies. The main thrust of the strategy is to.- introduce the topic of feedstock to MEPs, Commission and national government officials emphasise that new technologies should be encouraged clarify that there is no case for excluding feedstock from the directive's recycling definition by classifying it under energy recovery. 4.4. mandatory recycled content requirement Background Although the Commission proposal does not contain a requirement that packaging should contain a proportion of recycled material, the Environment Committee of the European Parliament is likely to adopt an amendment along these lines. The amendment is likely to establish the requirement and identify specific types of packaging which are exempt from such a requirement (e.g. food packaging) but will not specify percentage figures.. To counteract the high relative cost of recycled material in relation to virgin material, the proposal may be accompanied by a virgin material tax. APME Position APME opposes the introduction of a mandatory recycled content requirement on a number of grounds: it is likely to result in a reduction in product performance and consumer standards. Plastics in particular are likely to be incompatible with a recycled content requirement due to their great diversity and sophisticated specifications {there are over 30 different plastics in common use, each with some 50 different grade types) * it will raise the overall price of plastics against other materials, a cost which would have to be passed on to the consumer and would greatly reduce the likelihood of material choices being made on the basis of the highest standards for the consumer and the environment (ie the best material for a job) ; it will- be extremely difficult to determine relevant percentages for different materials -and to monitor enforcement of such requirements. Opposing views Although no Member State government has expressed support for the idea of a mandatory minimum recycled content requirement, the idea has support in the European Parliament and an amendment along these lines is very likely to appear in. the Report adopted at first reading in Strasbourg. It is not yet clear whether the Commission will support such an amendment but if they do it will CTL006631 be presented to the Environment Council ahead of their Common Position vote. APME Member Action To oppose any moves to introduce a mandatory recycled content requirement into the Packaging Directive. To oppose, if brought forward, a virgin material tax. 4.5. Energy recovery Background The Commission's primary environmental aim in introducing its proposal for a Directive on Packaging and Packaging Waste is to reduce the amount of waste going to landfill. The Commission proposal specifies a 90% packaging waste recovery target. By implication, 30% is to be recovered by methods other than recycling, ie energy recovery. The draft report by Luigi VERTEMATI MEP (Italy, Socialist) on the Commission proposal for a Directive on Packaging and Packaging Waste proposes an amendment which would place energy recovery below recycling in the hierarchy for packaging waste management. APME Position Plastics are a valuable source of energy. Plastics have the same calorific value as coal and provide 50% of all the energy produced during the combustion of municipal solid waste; at the moment most of this fuel is lost in landfill. APME believe that this energy should be harnessed by energy recovery: the plastics industry sees energy recovery as complementary to recycling; eco-balance studies show that for light weight plastics packaging which cannot be recycled with environmental gain, energy recovery is the most environmentally beneficial option; current technology enables all emissions to be dealt with safely. The plastics industry fully support^ the highest standards for clean municipal incineration and would like to see all incineration linked to energy recovery; the high energy value of plastics means that they have a key role in saving resources such as coal and oil during the combustion process. APME therefore oppose any move to reduce opportunities to use energy recovery and the placing of energy recovery below recycling in the waste management hierarchy. APME supports any initiative which creates targets which more accurately reflect the equivalence of recycling and energy recovery as waste management options. CTL006632 aPm e Opposing views The German Government is particularly opposed to any measures which seek to extend the use of incineration with or without energy recovery. Furthermore, the Green Group of the European Parliament is opposed to the increased use of energy recovery. APME Member Action To support by multiple activities the use of energy recovery as a waste management option. J 4.6. Restrictions on the use of certain materials Background The Commission proposal for a Directive on Packaging and Packaging Waste contains no restrictions on the use of particular packaging materials. However, certain political groups are using the opportunity presented by the proposal to introduce restrictions on the use and management of certain materials. In particular, they have focused upon chlorine-based materials. APME Position APME opposes any discrimination against any polymer not founded on sound scientific evidence: PVC is the best material for many different applications; PVC's low permeability to gases makes it ideal for packaging certain products and preserving fresh food; its low flammability is important for building and cabling applications, its long lasting mechanical strength and chemical resistance is necessary for pipework and fittings handling noxious chemicals and effluent and its purity is essential for contact with food, water and medical products; PVC packaging represents only 0.7% by weight of total domestic waste; PVC's chlorine content means that PVC is a source of hydrochloric acid (HCl) when waste is incinerated. Other contributors to HCl are food refuse, paper and wood. HCl emissions represent 2% of total acid rain; EEC Directives (89/369 and 89/429) require new incinerators from 1/12/1990 and existing incinerators from 1/12/1996 to be equipped with cleaning systems such as gas scrubbing and filtering techniques to reduce toxic emissions including HCl; independent studies including one by Professor Rappe from Umea University in Sweden show that " the elimination of PVC from the waste stream does not affect the amount of dioxins that occurs"; CTL006633 A# ME h over the last 5/6 years dioxin production has been reducea 1000 times by cleaning equipment in incinerators (a Danisn government study shows that all municipal waste incinerators contribute 39g dioxin per year; Denmark incinerates 70i? or its waste; PVC plastic bottles are easily recyclable into numerous long-life abdications. Collection schemes are alreaay m place to separate PVC bottles from other waste; Opposing views The Green Group of the European Parliament support a phased ban on the use of chlorine-based materials in packaging over three years. Whilst the rest of the Committee does not support a ban on particular materials, the Socialist group may well adopt an* amendment which seeks to prevent chlorine-based products from being incinerated. APME Member Action To support the non-discriminatory dimension-of the Commission proposal. To defend the environmental performance of PVC if proposals to restrict its use or management are proposed. CTL006634 Ausutka. Beigivrn. Cinoca. Dc.-wrur*. pw.irvi. Pr*nc#. Germany Grcce !r!and liiiy jacun Lu'xe^SCurg. Nstfitritnas. N#w Zetland. N'crway. Spam. Sweden. Switzerland. TumSt*. Rufj-a. Ukraine. Unned Kir.gdunt. USA embargoed 00.01 gmt 27th April 1993 S PVC IS A HUGE SOURCE OF DIOXIN, GREENPEACE REPORT REVEALS LONDON -27th April, 1993- A Greenpeace report released today as a global PVC industry conference convenes in BriQh:on,reveals alarming evidence that manufacturing PVC releases large amounts of dioxins and other toxic organochlorines into the environment. The report projects that the global production of vinyl chloride monomer (VCM), the building block of PVC, produces enough dioxin to give 8.1 billion people an annual maximum dose. "We demand that governments require the PVC industry to thoroughly investigate and identify all discharges of dioxins and other organochlorines from their plants,* said Lisa Finaldi, leader of the Greenpeace Chlorine campaign. "Local communities around these plants should be informed immediately of potential hazards to health." The report brings together nine case studies of factory emissions in four European countries; Norway, Sweden, Germany and the Netherlands. Measurements from one Solvay plant in Germany reveals an annual discharge of 8 grammes of dioxins into the river Rhine. Greenpeace argues there is no safe level for dioxin emissions. Even according to present international guidfines, 8 grammes represents a tolerable intake for more than thirty million people. In 1992, the US Environmental Protection Agency announced: "Recent data indicates that there may not be a threshold for certain responses to dioxin." Dioxins and other toxic organochlorines are some of the most potent carcinogens known. They have been implicated in nervous system disorders, foetal abnormalities and falling levels of fertility. The Greenpeace, report is released against a background of mounting concern about PVC and chlorine: * Evidence in the report has already resulted in the Norwegian Environment Minister blocking an application from the multinational PVC producer Norsk Hydro to expand PVC production at its plant at Rafnes, Norway. * Germany's State Environmental Ministers recently adopted a report which recommends the phase out of PVC in packaging and the building industry. * More th8n ninety municipalities across Europe including the cities of Berlin, Salzburg, Bremen and Unz have already banned the use of PVC in the construction of public buildings. "Greenpeace is exposing PVC for what it truly is - a toxic waste in disguise," said Geir VVang-Andersen, author of the report. "We demand the complete phase-out of the chlorine industry." FOR MORE INFORMATION Use Finaldi Greenpeace International 1-919-828-5202 Bob Edwards Greenpeace Communications 44-71-833*0600 CTL006635 NOTES TO EDITORS PVC production uses approximately thirty per cent of all world chlorine. Increasingly, international conventions like the Paris Commission regulating pollution of the Noah East Atlantic, and the International Joint Commission on the Great Lakes (USA &. Canada) are instituting phase-out plans for products and processes that emit organochlorines. P^.iPIX GREENPEACE COMMUNICATIONS, 5 BAKERS ROW, LONDON CC1R 3QB TEL: (44) 71 833 0600. FAX: (44) 71 071 837 6606. TELEX: 8953660 GPCOMM G Tfi 'iZ 0^c T^ty f0f3gJj sSnOiUiScEwD-ud HSU..,iy--g Sh0S-it>-t<L0 r Dioxin Factories: A study of the creation and discharge of dioxins and other organochlorines from the production of PVC.. <$teeH?fAC CTL006636 EUROPEAN- COUNCIL OF Vis'll. MANUFACTURERS A division of ihe Association of Plastics Manufacturers in Europe GREENPEACE DIOXIN REPORT 'RIDDLED WITH INACCURACIES', SAY EUROPEAN PVC MANUFACTURERS The European PVC industry has slammed Greenpeace International's recent 'Dioxin Factories' report as "riddled with inaccuracies". In a comprehensive critique, the European Council of Vinyl Manufacturers (ECVM) alleges that Greenpeace has made a series of gross errors which render its report null and void. ECVM alleges that, in charging the PVC industry with allowing huge emissions of dioxins from its production plants, Greenpeace has : - ignored published data which runs counter to its desired conclusions - misled readers by its presentation of data and toxicity information - conjured emotive conclusions from totally improbable calculations and scientifically unfounded extrapolations - sited manufactured plants in locations where they do not exist. "Greenpeace clearly drafted an emotive, attention-grabbing conclusion for its report and then worked backwards, selecting data to support that conclusion," said John Svalander, newly appointed ECVM Director General. CTL006637 Avenue E. Van Nieum enhuyse A Box A B-1I6H Brussels T i i r. phone ( 3 2-2 ) fi75 29 71 Fa c: si mile ( .12-2 ) 675 29 25 "The truth is very different - PVC manufacture poses no threat either to human health or to the environment. Its manufacture releases only minute traces of dioxins into the atmosphere and there is no evidence that these have any carcinogenic effect." The industry certainly does not claim that the data on dioxin formation and discharge are definitive, or that environmental impact cannot be reduced still further. "But", continued John Svalander, if "organisations such as Greenpeace chose to look, or if they accepted the industry's open hand of co-operation, they would soon find that there is a wealth of scientific information to demonstrate that dioxins from VCM production are not an environmental threat in themselves and definitely not when compared to the many other dioxin sources, which are much more difficult to control than those from VCM production." "By producing this misleading report, which lends a whole new dimension to the meaning of inaccuracy, Greenpeace has disqualified itself from holding the position of advocate for the environment." - ends -