Document O19KKZqrv3EGM5451dXYGmbr1

A Division of The Society of The Plastics Industry, Inc. Robert H. Burnett Executive Director February 16, 1993 TO: VI Executive Board HE: European Update Attached for your information and internal use is the report prepared twice a year by Rolf Buhl of EVC. If you have questions or need further information, please direct your inquiries to the Vinyl Institute or directly to the author in Brussels. RHB/pmb cc: VVIIG' OR Committee Chairs CTL006888 Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299 Fax # (201) 890-7029 |"i5M r>,;i I C*>,3 feSp iSsas '^rS'-k 'd^^StSSa* i.-^-r'va=^:5;*3f i2u 'WF >V?v- <* T-V^': /^smS :M w ,~<U\5 x& ..?i. ;;4<*5^SaS m \M sg S^fTs-v^ JSVv*^ "-*' v'^.V'-`v ^`>'''*4--`-t**t r- 7i;^ ^*-;v.;v"vV* r''.: V--.W- -^.-> .^. y*~ *-v- E^V'J;^'1^>*--.irviQV'<.^..^:o:'';^'-^;4v;* "> "-' :-:M-y^r^P^'l->K>:J:V:i::^^'-;'y.-" -V`;' 'j&SS&Sr&gMk ^m -'";->f-y..^>;`Y-'':V>-?t>'r,fiy-i-^i*S?*vr CTL006889 3.rr:- European Vinyls Corporation International SA/N V Bou'evard Cu Souveram 360 B-i 160 Bruxelles Belgium Tel (02)674 09 11 Telex 24 200 EVCB Telefax (02)660 11 31 From : R Buhl To : See circulation list 25 January 1993 UPDATE OF THE PVC RELATED ENVIRONMENTAL DEVEIOPHFNTS IN EUROPE AS PER JANUARY 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, since this could lead to misunderstandings. Last "update" : July 1992 TVa 429.153 632 CTL006890 M 1. AUSTRIA '- The regulatory debate about PVC is unchanged to what was the situation by mid-year, i.e. there has been no further discrimination or attempts to single out PVC. Emphasis today is on the "all packaging waste ordinance", signed by the Ministry in September to come into force by 1.10.1993. It allows the industry to establish a "dual collection and recycling scheme", following the German model. But more important, it accepts incineration with energy recovery in its recovery targets ! These targets are, for all materials : Recovery targets by 30.06.1995 by 31.12.1996 by 20.06.1998 by 31.12.1999 by 01.01.2000 40 % 50 % 60 % 70 % 80 % Plastic packaging waste for municipal treatment outside the recovery targets, primarily for landfill, will be limited from the present 245 ktons to 160 ktons in 1994 103 ktons in 1997 47 ktons in 2000 Within ARA (= Altstoffrecycling Austria, the recycling organisation for all packaging materials), there will be a plastics industry branch OKK (= Osterreichischer Kunststoff Kreislauf). The foundation process is underway, covering local producers as well as importers. Financing of collection and recovery will come from a disposal fee ("Lizenzgebuhr") to be paid by the consumer. The amount is not yet fixed. The court case against the Greenpeace billboard campaign "Stop PVC = Environmental Poison" showed only little progress in the October meeting between the two parties and the judge. Greenpeace failed to respond in time to the expert reports as submitted by industry and applied for postponement. In the follow-up meeting on January 25, 1993, the first witness from industry, Dr. Helga Roder from API, had to respond to questions from the judge and the counter-party. This will reverse at the next meeting, scheduled for May 1993. tloo 6891 2 The continuation of the PVC advertising campaign is under review. There will be a directional change by putting more emphasis on the social benefits of the product. Recycling API has published the results of the RWE survey on the PVC waste stream : against a consumption of 106 ktons in 1990, the total PVC waste rate at present is 40 %. Only 4 ktons are attributable to PVC packaging. 2. BELGIUM Almost overnight the PVC situation changed when the Belgian Government on 8.12.1992 declared it plans to charge PVC bottles with the highest ecotax of 15 BF, whether or not they are recycled. The ecotax proposal must be understood in the particular Belgian political context. The coalition government needs the support of. the Greens to carry through a major constitutional reform. The Greens have made their support for this reform conditional on .the government's acceptance of their ecotax proposal. .... r: The proposal originally taxed all non-refillable containers for beverages and plastic bags. Also included were provisions for batteries, paper, industrial packaging, pesticides, and disposable products such as razors and cameras. The Belgian government, recognising the incompatibility of their proposal with the proposed EC packaging directive, negotiated with the Greens to remove the discrimination between refillable and recyclable containers, i.e. to accept recycling as equivalent to refilling and subject to the same rules. The tax on plastic bags was examined from the perspective of its economic impact on Belgian industry. Because of the recognised impact, the present agreement does not include such a tax. Further negotiations will be held on this point. With regard to bottles, the agreement between the political parties as per 8.12.92 was an ecotax on all containers for carbonated drinks, beer, and flat and carbonated mineral water, to be applied from 1 January 1994. Key elements of the tax (Appendix 11 are : * no tax charge on packaging that is refilled provided that there is a deposit (BF 7) on the packages and that high targets for refill are met* * a scaled tax on non-refillable packaging provided that the producer or importer proves that the packaging has been recycled to rates of : CTL006892 3 glass 80% plastic 70% steel & alumin i urn 100% ' ' targets nus t be reached according to the followingtable 1993 : 1994 : 1995 : 1996 : 1997 : 12% of the population 32% 55% 80% 100% ' * * - :; financial responsit>i1ity for collection, sorting and ling lies with the "producer" or "importer". Incineration is not considered as recycling. (Note : this does riot mean that incineration is not allowed; it means that energy recovery cannot be used to reach recycling targets. This is compatible with both the EC proposed directive on packaging and with the APME acceptance that recycling (material and feedstock) and energy recovery are two separate means of managing waste. The industry would like to see these options be considered equally : valid.) * The highest rate of ecotax (BF 15 per litre) will be applied to PVC, with no exemptions for recycling. The specific discrimination against PVC entered the political negotiation at a sudden and late stage, i.e. on 8.12.1993, after the ecologists had compromised certain of their more extreme positions. PVC then became the key element in determining the Greens' support to the government. Prior to that, the Belgian member companies of APME as well as the Chemical Industry Federation in Belgium and its plastics division, the Belgian employers' federation and numerous other interest groups had been, from the time of the initial proposal, active in combating the ecotax in all aspects. The agreement of 8 December then led to the following industry actions ; * Representatives of the local producers Solvay, LVM and BASF met with the Prime Minister to protest against the PVC discrimination and requested neutralisation.* * PVC industry employees from all over Belgium demonstrated in the streets. This led to very significant media coverage in the press, radio and television, with workers claiming that their jobs were threatened by discrimination against PVC with no environmental justification. CTL006893 4 * Because the principal effect of the de facto ban on PVC bottles is to exclude French mineral water from the Belgian market, Elf-Atochem and the French mineral water producers are provoking a reaction by the French government viz-a-viz the Belgian government; The EC Commission's DG III has indicated to the Belgian government their concern regarding this obstacle to trade. EC opposition to a final Belgian proposal would probably go beyond the discrimination against PVC, including the fiscal base itself, may well be judged incompatible with EC law. Against this massive opposition, the Belgian Government met with the Greens on January 16 1993 and agreed (according to media reports, no official text published so far) : * Implementation date for the ecotax specific to PVC to be postponed from 1.1.94 to 1.6.94. * An expert commission to prepare a specific report on the effects the PVC ecotax will have on employment (economy and ecology) to be published by 31.12.93. The results will be used in the final vote by parliament. Recycling Collection of PVC bottles is increasing. During 1992 Solvay will have recycled some 350 tons (a 50% plus over 1991). 3. DENMARK No particular news, except that, following pressure from the European PVC producer, the Environmental Ministry shows first signs to reconsider the "anti-PVC agreement". However, no initiatives have yet been taken. The PVC industry has moved its local task force from "APME-DK" into "The Danish PVC Committee" under the umbrella of Norsk Hydro, to provide a more focused response to the authorities. More general, the Environmental Ministry's new "Waste Management Programme 1993 - 1997" aims at altering the balance of household waste disposal from today's 8% recycling, 75% incineration and 17% landfilling to 40-50% recycling and 50-60% incineration and landfilling by the year 2000. Recycling Nothing new to report. CTL006894 5 4. FRANCE Still no major anti-PVC attacks from either the authorities or pressure groups. The debate within the plastics industry . concentrates on the waste management decree for used packaging as per 1 April 1992 and its transformation into practice. The Environmental Ministry has approved "Ecoemballage" and its ; subbranch "Valorplast" representing the plastics packaging vry industry. Details are given in Appendix 2. Interestingly,' >:- 3 Ecoemballage agreed with DSD in Germany to use the same "green dot" symbol. The French and German Environmental Ministers have also met to announce their cooperation when regulating waste from used cars.' Recovery of plastic parts is getting a high priority. Against this background the French car industry is working on PVC substitution "to avoid problems when incinerating the shredder waste". Recycling With reference to the above packaging decree, Valorplast has guaranteed to the municipalities to have a total of 40.000 tons of plastic bottles (PE, PVC, PET) recycled in 1996. 5. GERMANY The BLAU Committee, consisting of representatives of the 16 federal environmental authorities have completed their report on the environmental impact of PVC and presented their findings to the Environmental Ministry. Whilst the factual analysis by and large is acceptable to the industry, some of the recommendation as approved by the Ministry in November requires counteraction : * Reduce the amount of PVC entering incineration (top priority) * Substitute Cd and Pb stabiliser as soon as possible * Substitute PVC products which cannot be collected or recycled for technical reasons (reduce production of virgin PVC) * Stop use of mercury and asbestos in brine electrolysis. Industry is asked to meet with the BLAU Committee and to prepare for voluntary arrangements. There is a relationship between the BLAU Committee and a draft ordinance for the treatment of municipal waste ("Entwurf TA-Siedlungsabfall"). Against protests of the plastics/PVC industry, this draft passed the Cabinet of Ministers in August, still containing the clause "to eliminate PVC, PCB and other problematic materials before entering the incineration process". Closing the landfill option at the same time, this ordinance, when put into practice, requests to first stop processing PVC and CTL006895 ji EE 5?: - r 'a `i 6 ultimately to stop manufacture ("there is always waste, even with recycling"). -:. In an intensive campaign opposite the regulatory authorities, industry was able to negotiate a "neutralisation of the PVC clause", though the final vote of the Federal Chamber (Bundesrat) is still pending. One of the arguments used by the industry was "to consider a closed loop PVC scheme", managed by the PVC industry and financed, similar to the Duale System for packaging waste, by a disposal charge on top of the end product selling price. As per today, the PVC industry is optimistic that a final vote will be in favour of PVC. Discussion today concentrates on the feasibility of such a closed loop scheme and, more important, the voluntary participation of all member companies, including the importer ! Against this background a recent statement by Toepfer is attached (Appendix 31 : No regulatory ban on PVC but the expectation that the PVC industry demonstrates responsible care and manages its waste stream. Much media attention was given to a fire at a recycling plant at " Lengerich, involving some 1500 tons of plastic, incl. PVC. Aside HC1 emissions, Greenpeace reported excessive dioxin formation from burned PVC, leading to the evacuation of the neighbourhood. Experts were brought in for measurements and concluded, that^with dioxin deposition values in the range of 0,08 to 5,6 ng TE/ni there has never been a danger to the public ; the tolerable level by the health authority is 5 ng TE/m. Greenpeace used this fire to launch a further anti-PVC campaign with demonstrations at the EVC, Solvay and Hoechst PVC plants. The public hearings, provoked by Greenpeace and attended by industry experts, failed to bring public credit to Greenpeace. Reeve!ing In its attempt to widen the capabilities to recycle PVC, the manufacturers of roofing membranes formed a consortium, called AFDR : it follows the model of AGPR, the flooring recycling consortium, and will organise and finance the collection and recycling of used roofing membranes. Monocombustion of PVC waste with HC1 recovery is another activity initiated by the AG-PU as a means of feedstock recycling. A feasibility study is underway and the results will be fed into the beforementioned "PVC closed loop concept". Behind the HC1 recovery project is also the fact that the German recycling targets as laid down in the Toepfer packaging waste ordinance will (most likely) not be met in 1995. As a consequence, the plastics industry and DSD are strongly pushing "feedstock recycling technologies" to close the gap. First large scale CTL006896 7 experience will be gained in 1993/94, when the hydrogenation plant in Bottrop, run by VEBA Oil, will have processed some 40 ktons.-.:.^ This process is more tolerable to chlorine containing feedstocks, but much more of such capacities are needed to manage a 700 ktoris plastic packaging waste mountain in 1995. The other feedstock recycling technologies to recover hydrocarbons have tight : rev specifications on the chlorine content, down to below 1 ppm (Appendix 41. These processes wish to see PVC separated from the waste stream and to organise its own "PVC waste management scheme". ... r* .v r, Some facts on the "green point DSD/VGK" plastic packaging recycling scheme as per year end 1992 : r = -/ * All 16 federal countries contracted by DSD (though some conditional) * 126 DSD sorting plants to separate plastics for recycling via VGK * 63 plastic recyclers iii Germany and abroad are certified by TUV (= Technical inspection authority), with a total capacity of 127.000 tons in 1992 and 200 000 tons in 1993. * About 38 000 tons of plastic packaging have been recycled in 1992 (1.200 tons in 1991). * To achieve the 9% recycling target in 1993, some 80.000 tons are to be recycled. 6. HOLLAND Since the "Packaging Covenant" dated back to 1991, there are now signs that the PVC position is gradually recovering, at last has stabilised. A meeting in August between PVC industry and the Environmental Ministry concluded not to discriminate PVC any further and to give the industry the chance to demonstrate its improvement programme, particularly with regard to waste management. It is in particular the latter, where the competing industry seems to have learned that they must work together instead of against each other or against particular material (ref. : Packaging Ordinance, PVC). A good example is the FKS pipe recycling initiative, jointly covering PE, PP and PVC. The city of Breda has been chosen to make a start with the collection and recycling of plastic packaging waste in order to fulfill the above Covenant. 7. ITALY The parliamentary process to regulate waste managment, and here in particular the waste from industry and from used packaging is gaining momentum. Within this the decree for bottle recycling (Law CTL006897 8 475/88) is to be extended to an all packaging decree, matching up with the EC draft directive on packaging waste. Attempts are made to restrict PVC from incineration or to ban it as a packaging material. The PVC Working Group within Assoplast, consisting of EVC and Solvay representatives, was able to prevent such discrimination. A draft document (Ref. : 1840, Nov. 1992) :is now with industry to reach final agreement on the waste treatment ' conditions. . , -.< - , j Much media attention was given to test reports on mineral water, bottled in PVC, PET and glass, with PVC to come out worst : changes in colour and high migration. The PVC industry reacted immediately and questioned the applied test conditions and the neutrality of the test laboratory. A legal case against a further distribution of the report has been filed by Solvay, too. Both Assoplast (Association of plastic manufacturers) and Unionplast (Association of converters) has been requested to oppose to such unfair and biased "green product marketing". It is probably no coincidence that this report was published at a time to support some pariiamentarists to regulate against PVC ___ Fiat has announced its recycling philosophy : * preference to plastics with re-use/recycling opportunity * reduction of polymer types * design for recycling * substitute PVC wherever possible, but not as underbody sealant The Assoplast PR campaign now includes a single page "Fact Sheet on PVC", issued bimonthly and distributed to all leading newspapers and press agencies. Reeve!ino Tecoplast has reached a contract with Replastic, the industry consortium, to process some 4 ktons PET and PVC in 1993. However, it is a fact by now that Replastic will be unable to reach the 20% bottle recycling target fixed for 31.3.1993 in Law 475/88. This made Replastic to negotiate with the authorities (in order to avoid a levy of 100 Lira per bottle). Official agreement was reached to postpone the target to 31.3.94. 8. LUXEMBURG Nothing new to report. 9. NORWAY Nothing new to report. 10.SPAIN Nothing new to report. CTL006898 9 11. SWEDEN Still a strong and steady attack by Greenpeace on chlorine chemistry and PVC, now focussed on all municipalities. Their timing fits well with the Swedish Government plans to come forward with a new waste management decree. Closed product loops are elements of this draft, but there are also rumours that it will contain some very specific anti-PVC targets. The PVC industry has requested to become consulted, but found it difficult to get its messages across or to commit the Ministry to a factual response. To progress this matter and to get attention, full page adverts were placed in the major daily newspapers. Equally, all members of the Parliament were informed of the PVC industry's need for consultation. As a result, PVC is now vigorously being discussed amongst all parties, not allowing the Greens to dominate the regulatory process. Greenpeace also distributed a press release, claiming the annual release of 320 g dioxin in VCM by-products from the 110 kton Stenungsund plant. What Greenpeace hid from publication is the fact that this dioxin level is prior to on-site waste treatment, reducing this to an emission of 0,2 g dioxin annually. Reeve!ing Nothing new to report. 12.SWITZERLAND As reported earlier, the Swiss Federal Court rejected on July 7, 1992 all the appeals from industry and confirmed that the ban on PVC beverage bottles is in line with the Swiss waste management decree. There is no question that this judgement is based on politics rather than facts : * Legal bases : the court accepts that PVC bottles are causing neither pollution of air nor water. However, the Court argues that 10% of the chloride in incinerations derives from PVC bottles and seriously hinders waste incineration. What about the other 90% ? * Proportionalitv : the ban on PVC bottles is not proportional since the bottles do not hinder waste incineration (this was also confirmed by a chemist in a Zurich incinerator) and since it is possible to recycle PVC bottles.* * Discrimination : the Court says that PVC bottles must be banned since their pure existence complicates recycling of PET bottles. Our evidence that the different bottles can be separated and recycled, or can be recycled as mixed plastics, were not taken into consideration. CTL006899 10 * Good Faith : The Court accepts and confirms our arguments and states, that the Federal Department of the Internal Affairs (DFI) should have rendered the decision we were seeking during months. The way through the offices of the different cantons was, therefore, unnecessary and a result of the DFI's lack of good faith. * Free Trade Agreement (FTA1 : The Court apparently joins the view of the Federal Department of Foreign Affairs (DFA) that PVC bottles qualify as agricultural - rather than industrial (!) products and denies protection under art. 13 FTA. This view is simply absurd. * EFA Agreement : The Court only states that the EEA Agreement is not yet in force. It ignores that Switzerland is not allowed to enact law which contradicts the EEA Agreement. A letter of protest was sent to the Minister, but the Swiss referendum of 6.12.1992 to not join the EEA pre-empted much of the arguments to secure free trade and to align with a European harmonisation process. The local PVC Working Group therefore proposes to close the legal files opposite Minister Cotti, but to keep the debate going at EC level. Recycling Progress is being made to bring together the plastics industry into a nationwide plastics waste management scheme. A foundation process to establish the "Schweizerische Stiftung zur Reintegration von Kunststoffen" is underway. The PVC industry will use the "PVC Bottle Recycling Group" as its initial forum for participation, but will open it to other applications and member companies. 13.UK In the UK, too, waste management is moving up on the political agenda, with a focus on municipal/packaging waste. Industry has to organise itself in a manner to represent its interests. A Consortium of the Packaging chain (COPAC) was founded and presented its six-year plant to the Government (Appendix 5). Competition to COPAC has come in recently in the voice of "The Packaging Federation", a trade body for packaging manufacturers only. Experience in other countries has shown that industry must speak with one voice only or will fail to get its message through. A most important task for the PVC industry in the UK is now to get its act together and to protect its interests, preferably under a BPF umbrella. Ecolabelling of building products is a project of BRE, the Building Research Establishment, sponsored by BRITE/Euram programmes and coordinated by the European Network of Building Research Institutes (ENBRI). This is an excellent opportunity to get an ecolabel for CTL006900 11 PVC building products such as windows, pipes etc. Life cycle analysis will form an essential part of the project. Manufacturers of PVC building products, supported by their suppliers, indicated already their interests to participate in the 3-year project. Recycling 3 v Imported, but subsidised plastic packaging waste from Germany is disrupting the infrastructure of the local recycling industry. Subsidised waste gets clear preference by the recycler to improve the economics of his operation. EVC-Reprise already announced strongly the need for a wider finance base for its bottle separation plant, namely from the PET and PE industry to ensure that these product streams are used viably, too. To continue this negative development will eventually force EVC to close down Reprise with the consequence that many bottle banks in the UK have to close down, too. 14.DEVELOPMENTS AT EC LEVEL' The "draft EC Directive on Packaging and Packaging Waste as per 15.7.92" is being debated at national level. The Council of Ministers started discussion, too. APME is drawing much attention to this process and contacted some 200 MEP's already with is position paper (for details : Appendix 61. One particular objective of this campaign is to get the 60% by weight for each material changed into 60% for all packaging, or to differentiate plastics from the other materials. There are also plans to invite some key MEP's on a tour to selected demonstration plants (material and feedstock recycling, energy recovery) in Europe. The time table for the EC is to have a "draft opinion" ready by March 1993 and the 1st plenary reading in May 1993. As one could expect, Greenpeace approached the European Parliament with the request to phaseout "chlorinated packaging materials". An industry response is being prepared. APME/PWMI took the occasion of K'92 to announce the plastics industry's waste strategy for the next 10 years. Within this, a pan-European bottle recycling programmen, covering PE, PVC and PET was launched. The national organisations are asked to prepare for collection, sorting and recycling, wherever appropriate to build on established schemes such as DSD/VGK in Germany, Ecoemballage and Valorplast in Erance or Replastic in Italy. All APME member companies have committed themselves to participate, supporting each market in which they are active. A key to this approach will be fairness amongst the competing polymer producers, particularly when it comes.to agreeing on the finance schemes. 15.OTHER EUROPEAN DEVELOPMENT For the first time, the West European PVC producer met with the East European PVC producer in a conference at Budapest in November to create working relationships on safety, health and environment. CTL006901 12 < Waste management was one of the key discussion points. Working groups will be set up to take such tasks further. Interestingly, the only country so far which is forced to act on post-use PVC s (packaging) in Eastern Europe is Poland, where the Government requires industry to come forward with a recycling concept, otherwise to limit usage. srv r* There are also attempts'.to scale up the relations on SHE matters at a global level by bringing together the European, American and Japanese PVC producers. This is a reaction to global environmental conferences or conventions (Oslo, Paris, Rio), where attempts are made to discriminate against chlor-organic compounds, and to which industry has to react equally on a global scale. viwi-i R. Buhl RB/hs/009 (with input from ECVM and the EVC Environmental Committee) January 25, 1993 Enclosures : Appendices 1 to 6 CTL006902 k/ flrP/6t?J/ tf <&?.. $/. ?JL ' 20 F i-t*. Toil"consigne de 10 F) * \\ `..A .. .'V * t *' "*1 Rasoir jetable ; 10 F 1 jw.* v *>|-*'vr>. V`/<' -'"X'ACpapM'a&r*e~i<l p.*h'<o-&to*J\ei<tab'4le*"' dSOOF^^;^^;'; Vi'll:.1.'Jr.-'.i" Emballage de pr'oduit 25 F/litre. ' OF pour . . Industriel/pesticide .;' (maximum = 500 F) ('emballage consigne 'de 2 a lOF/gramme de substance active Emballage de boisson 15 F/iitre (eau petillante, biere, (minimum = 7 F) limonade) -mini. OF : si consigne de 7F . au'moins poiir emballage " deplusde50d ._.(m'ao^ints.Vde S..O d = 3,5 F) ' si le producteur atteint un taux de recydage/ reutilisation suftisant sans possibiCte de;;:,i.'. reduction ou cTexoneration Carton/papier fai i4 H\zr*c\ . 10 F/kilo i*-1, .t SFpiO- 7*/<5?? -`Sisi*/. ,* v.-V ^.Vv ry<c1..: si pate non blanchie au'ehlore gazeux dj{. 'I.' L' si le producteur atteint un laux de recydage suttisant CTL006903 Prof. Dr. KLAUS TOPFER, MdB D USDESSUSlSTER FUR UMWEL.T, NATURSCIRITZ UND RAKTORSICHERJIEIT 5300 Conn 2, den 2 i. 12. 32 Kennedyallcc 5 /Melon: (02 2S) 30S-2000 ' 'und 305-2001 Verband .-r..;- Kunsfcstofferzeugende Industrie e. V. Herrn Hauptgeschaftsfiihrer Roger Kamps Karlstr. 21 6000 Frankfurt am Main Sehr geehrter Herr Kamps, fur Ihr Schreiben vom 14. September 1992 Vu"r Frage eines PVC- Verbotes danke ich Ihnen. Ober PVC wird seit~langerem.sehr. kontrovers diskutiert, einige fordern den Ausstieg aus der PVC-Produktion. Zur Klarung der Frage, ob PVC Belastungen der Umwelt verursacht, die staatliches Handeln erforderlich machen, ist der Bund-/Lander-AusschuB fur Umweltchemikalien (BLAU) beauftragt worden, in einem Bericht mogliche Umweltbeeintrachtigungen durch PVC bei der Herstellung, Verwendung, Entsorgung und Substitution zu untersuchen und zu bewerten. Recycling pjpier, >u 100% bus Allpjpier hcrgcttelM CTL006904 2 i:-!^' * " : Dieser Bericht ist nunmenr f ertiggestellt und von der tfvJV nisterkonferenz am 19./20. November d. J. zur Kenntnis'genofnmen^^;--'/ worden . . -. 'A Der Bericht kommt zu dem Ergebnis, daB PVC weniger bei der stellung oder bei der Verwendung Probleme bereitet als bei `der^5^* Entsorgung. ' Insbesondere in diesem Bereich wird Handlungsbedarf gesehen, wobei prioritar die kurzlebigen Produkte weitgehend zu substitu- ; ieren sind, um den Chloreintrag in die Hausmiillf raktion oder | vergleichbare Reststoffmengen zu minimieren. ...... Bei Nutzungsende langfristiger PVC-Produkte (Fenstern, Rohren, ' Bodenbelagen u. a.) sollen die Abfallmengen durch weitestgehende ; . Verwertung zur Produktion vergleichbarer Erzeugnisse verringert werden. Hierbei ist entsprechend dem Grundsatz der Schadstoff- entfrachtung auf die Verwendung (oko-)toxischer Additive soweit wie moglich nach dem Stand der Technik zu verzichten. Die-Umweltministerkonferenz'setzt sich fur eine ziigige Umsetzung der vom BLAU vorgeschlagenen MaBnahmen ein. I Hierbei setze ich auf die Kooperationsbereitschaft der betroffe-- nen Kreise der Wirtschaft, so daB ein generelles Verbot von PVC aus heutiger Sicht nicht qeboten erscheint. Ich bin zuversichtlich, die jetzt fur erforderlich gehaltenen MaBnahmen zur unbedenklichen Nutzung von PVC-Produkten mit alien Beteiligten auch ohne ordnungsrechtliche Eingriffe umsetzen zu konnen. Mit freundlichen GriiBen CTL006905 THE OPTIONS FOR CHEMICAL ("FEEDSTOCK") RECYCLING! OIL/NAPHTHA GAS COKE OIL CTL006906 The Industry Council for Packaging and the Environment Recycling Targets COPAC plan welcomed by... Government The UK Consortium of the Packaging Chain (COPAC) has pre sented the Government with a detailed plan showing how its published recycling targets could be achieved using a marketdriven approach, without the inflationary costs inherent in other recycling systems, notably the German Dual System. The COPAC six-year plan commits the industry to: triple current household recycling to 339c increase payments for collected and sorted used packaging from 72m per annum to 177m per annum invest nearly 600m to achieve this. The plan identifies a number of key areas where commitment and action are required from Government, notably in countering the impact of subsidised prices for recov ered materials in other European countries. In presenting the plan to Lord Strathclyde, Parliamentary Under secretary of State at the Department of the Environment, COPAC Chairman Tony Baden Fuller also called on other industries who contribute recoverables to the waste stream to work in partnership with COPAC and the Government to achieve effective, low-cost recycling. The main points of the plan are: It addresses the Government's target of recycling and composting 25% of household waste by the year 2000 and COPAC's commitment to assist in achiev ing this. If a specific packaging target is called for. COPAC has set an objective that 50% of used packaging will be divert ed from landfill by 2000, given appropri ate collection and sorting facilities. Realistic forecasts prepared by COPAC indicate that the packaging industry's own plans will lead to 42% recycling of all packaging (of which 33% is household w aste) b> 1999. The target would increase w ith composting and energy-from-waste facilities. The target is based on the pre requisite that one-half of UK households have access to collection systems. By 1999 packaging material proces sors w ill increase payments to waste col lectors and local authorities for collected and sorted used packaging from 72m per annum to 177m per annum, and spend 50m per annum on capital invest ment over this period. The plan identifies a number of over riding and sector-based constraints on achieving and subsequently exceeding the t 42% recycling figure. An over-riding constraint is the need to keep demand for reclaimed materials in line with supply. and the development of end-use markets is crucial. It is also essential to counter the impact from other parts of Europe of subsidised prices tor recovered materials. COPAC calls for government com mitment and action to achieve the plan's objective, particularly in working towards free, unsubsidised markets for recycled packaging materials and accelerating the development of end-use markets. COPAC members arc developing the details for short term activities in the area of research and development projects involving collection and sorting in the context of integrated waste management systems, recycling, reprocessing and new end-use markets amounting to 16m per annum. COPAC's target will be reviewed in the light of experience when the results of the short term research and develop ment programme are available. Further information and copies ofthefill COPAC Plan are available from the htepen office. November 1992 ,r i< >. ' - CTL006907 %: RESOURCE OPTIMISATION ac:.. vva-/ . . := The growing European Community waste mountain is a central issue for the European plastics industry. APME is committed to the pursuit of resource optimisation throughout the life cycle of plastics ending with an integrated waste management policy to ensure optimum recovery and conservation of natural resources. Independent eco-balance assessments support this integrated approach and show the need to treat each circumstance individually to determine how best to achieve net environmental gain. Resource optimisation criteria'are applicable throughout the life cycle of plastics: from raw material production with priority on prevention, through reduction and re-use and finally to recovery at the end of life by recycling and energy recovery. . EC POLICY AND THE PLASTICS INDUSTRY Our resource optimisation policy directly supports the European Community hierarchy of waste management as set out in the Community's Strategy for Waste Management and the Commission's Fifth Environmental Action Programme as well as the framework Directive on waste (75/442/EEC amended by 91/156/EEC): EC Hierarchy -3Plastics action Prevention of the production of waste through reduction and re-use Recovery of the waste produced ' Or Safe disposal 3 b* through recycling and energy recovery plastics can be disposed of safely in landfill but only as a last resort This integrated policy provides the crucial flexibility required for optimum waste management solutions, environmentally and economically. The rest of this paper follows the European Community's waste management hierarchy, demonstrates how resource optimisation maximises net environmental gain and examines the Packaging Directive in the light of these policies. CTL006909 PLASTICS PACKAGING WASTE REDUCTION APME is committed to the European Community's main objective of reducing the amount of waste. The European plastics industry is constantly reducing the amount of material used and increasing the life of products to reduce the volume and weight of waste, as well as conserve raw materials and energy. *` 1 V-v-' ` . ' ,'S Plastics packaging is up to 80% lighter than twenty years ago through a combination of better raw materials, improved converting techniques and more efficient design. Reduction of material -at the manufacturing stage "lightweighting* - is particularly appropriate for plastics' combination of strength and lightness. Examples of lightweighting and design efficiencies include the following: * a 125g yogurt pot (without lid and metal foil) weighed 6.5g in 1968. By 1990 this was reduced to 3.5g; * a T-shirt bag weighed 23g in 1972. By 1990 this was reduced to 6.5g; plastics refill pouches, eg liquid detergents, represent a reduction in packaging of more than 70% in weight compared with a typical bottle of the same volume. The refill principle also ensures re-use of the original container. THE EC COMMISSION PROPOSAL Design improvements such as lightweighting have already done much to meet the Commission's objectives of: minimum material quantity without impairing product safety and quality; * product design, production and marketing to minimise environmental impact. In Switzerland milk is now frequently sold in a lightweight refill pouch. Earlier drafts of the Directive included per-capita packaging reduction targets by weight, often known as the "standstill principle". APME does not support this approach which would; hinder economic growth across Europe; jeopardise the improvement of living standards in less well-developed European economies; create enormous problems of measurement and implementation. CTL006910 PLASTICS PACKAGING RE-USE Plastics packaging is widely re-used: applications include drinks crates, pallets, carrier bags and milk bottles; :V one UK retailer reduced plastics bag usage by over 60 million a year through a Ip > refund on every reused bag, saving 1000 tonnes of plastics; a plastics packaging system has been developed which acts as transport protection and an in-store display case. The system is calculated to stand up to 100 trips giving it a 10 year estimated life. .2 However, the net environmental gain and logistics of re-use systems have to be given careful consideration: If a product is re-usable but requires excessive energy to make re-use possible an alternative recovery process may be more environmentally beneficial; prices will have to rise to meet the increased storage and personnel requirements placed upon retailers; the storage of re-usable packaging creates the risk of bacteriological contamination ; in particular environments (eg food storage and display); many applications require the higher hygiene standards that disposable plastics packaging offers. - THE EC COMMISSION PROPOSAL Recital 5 of the Packaging Directive's preamble states that: '..as long as life-cycle assessments justify no clear hierarchy, reusable packaging and recoverable packaging waste and, in particular, recyclable packaging waste are to be considered as equally valid methods for reducing the environmental impact of packaging.." APME support reuse systems alongside reduction and recovery to achieve resource optimisation and net environmental gain. CTL006911 PLASTICS PACKAGING WASTE RECYCLING Recycling is a key recovery and resource optimisation 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: - in many instances where mechanical recycling is possible, the energy and other resources consumed outweigh the environmental gain. Much of plastics packaging is extremely light weight (in France, 70% of plastics packages weigh less than 3g); French studies show that it takes more than 150 yogurt pots to produce less than 1 kilo of recycled plastics. The light weight, dirtiness and mixed form of much plastics packaging waste means that the energy costs of washing, sorting and transportation outweigh the environmental benefits of recycling; Recycling plastics bottles can result in net environmental gain. Greater weight and rigidity mean easier and more efficient collection and cleaning, and less energy is used in transportation. Industry efforts are focused on this area. The European plastics industry aids packaging recycling in the following ways: design for recycling - to enable material identification in the separation and sorting of plastics waste and a world-wide coding system; new recycling approaches - such as feedstock recycling, the "unzipping" of plastics molecules to return them to basic materials which can be used again as feedstock for plastics products or in other petrochemical and chemical processes; stimulating new markets for recycled plastics - recycled material with no end-use represents a waste of resources. THE EC COMMISSION PROPOSAL The current proposal sets a recycling target of 60% by weight for each material. The setting of a recycling target will hinder the optimisation of resources because: it is incompatible with the Directive's philosophy of equally valid recovery options; it will prevent the choice of the most environmentally appropriate recovery option; it will reduce short term capital investment in other waste recovery technologies. Earlier drafts set recycling targets for all packaging rather than for each material. APME supports a return to these targets because: there is a lack of information about the optimal level of recycling. Recycling is not always the best option as it does not always effect greatest environmental gain; packaging materials are vastly different in composition and weight and therefore identical targets are unrealistic and discriminatory; targets for all packaging allow flexibility to choose the most appropriate recovery option for each material. Pm,v: H p* * ",<*^^ > * ,f* <*A`A'V* STf CTL006912 PLASTICS PACKAGING ENERGY RECOVERY Plastics are a valuable source of energy. Plastics have the same calorific value as coal end 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, not as an alternative; 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 supports 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: * in France during 1990, 450 000 tonnes of oil equivalent fuels were saved by the use of MSW incineration; * in Dusseldorf the local energy recovery programme replaces up to - v' 60 000 tonnes of oil each year; . * up to 5% of domestic electricity could be generated by MSW, saving about ' half of the coal imports to Western Europe; separated plastics waste can be formed into high calorie fuel pellets known as refuse derived fuel (RDF) which are widely used in industrial processes. THE EC COMMISSION PROPOSAL The Commission's primary objective 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. Energy recovery can reduce the volume and weight of waste which would not be recycled but would be consigned to landfill (by up to 70% and 90% respectively). Countries with a strong environmental track record like Denmark (where 80-90% of all waste is combusted to provide energy) and Switzerland (where a further 10 energy recovery plants are being built) all rely on energy recovery to reduce the amount of waste going to landfill and to recover energy for other purposes; y. * 27 million tonnes of waste are combusted to produce energy for heating and lighting in Europe; ", energy recovery can contribute to a saving in the consumption of fossil fuels. An / increase in the amount of waste used to generate energy by just d save _ over 2 million tonnes of coal a year. If all of Europe s waste was use to energy it would provide 3-4% of Europe's domestic electricity nee s- - CTL006913