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EU end-of-waste criteria for glass causes confusion among glass reprocessors

New criteria on when glass cullet can no longer be considered waste have come into force last week as part of European end-of-waste regulations.

The EU Regulation no. 1179/2012, which was adopted in December 2012 and came into force on 11 June 2013, establishes criteria determining when glass cullet, which is scrap glass gathered for remelting, ceases to be waste and obtains a status of a product or secondary raw material.

This followed an evaluation that recycling markets for glass would benefit from the rules, said the European Commission.

‘Freer movement’ for cullet

A Defra spokesperson said: “We believe the new regulations will benefit glass recyclers and the glass industry as a whole, particularly by reducing costs relating to the movement and trading of glass cullet and by providing an incentive to improve the quality of material.”

Phil Conran from 360 Environmental explained: “By taking processed glass cullet out of waste regulatory control it is no longer a waste but a product, which means it does not have the same barriers to transportation and shipping as waste, such as transfer notes and licences under the Transfrontier Shipment regulations.

“This should allow freer movement of the cullet and allow it more easily back into the economy, with businesses that use it no longer having to be permitted.”

High quality thresholds

In 2012, MRW reported that the Commission’s Technical Adaptation Committee (TAC) ruled that glass cullet had to be of a high enough quality that it could be used for remelting into materials including bottles and fibreglass.

According to the new criteria, glass cullet can only be considered waste when the content of non-glass components are above the following thresholds:

  • Ferrous metals: 50 ppm
  • Non-ferrous metals: 60 ppm
  • Non-metal non-glass inorganics: 100 ppm for glass cullet size > 1mm; and 1,500 ppm for glass cullet size ≤ 1mm
  • Organics: 2,000 ppm.

The regulation also sets out that producers or importers of glass cullet have to issue a statement of conformity for each consignment of glass cullet, and prescribes that a “conformity assessment body” or an “environmental verifier” should monitor the system put in place to comply with the new rules.

But there are a couple of big question marks over how the regulation applies to the glass recycling market in the UK, which Conran said places the market ‘in limbo’.

Call for guidance

Currently PRNs can only be issued for waste. Once glass cullet recyclers declare their cullet as ‘end-of-waste’ that will mean it is a product, not waste. Therefore big glass reprocessors will not be able to issue PRNS on receiving this cullet, meaning PRNs could be lost.

But under the end-of-waste regulations, the medium-sized glass recyclers such as Berrymans and Recresco, which produce glass cullet for reprocessing, can become accredited to issue PRNs. Conran argues that not enough is known about how the PRN system for glass will operate with the new rules in place, and further guidance on “the agency’s expectations of processors supplying end-of-waste to supply PRNs” is needed from the Environment Agency (EA).

Conran told MRW that the other major issue is the lack of Defra guidance on the quality management system in place for end-of-waste glass cullet. Accreditation to be able to declare your cullet as end-of-waste is required but it is not yet clear who will be issuing it or what certificaton is going to be required.

Rebecca Cocking, head of container affairs at the British Glass Manufacturers Confederation, told MRW she believes that the glass cullet end-of-waste accreditation process will be managed by the UK Accreditation Service (UKAS), to which one company has already applied to obtain accreditation.

“I believe companies [producing glass cullet] will see the financial benefit of writing PRNs and they will want to become accredited [for end-of-waste status for glass],” she added.

Defra said it will issue guidance to the industry shortly to help answer questions about the new regulations.

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