ANNEXE 1.DOCUMENTS ABOUT SEPARATE COLLECTION.
1. PAPER NR 1 ZEKI MUSTAFA
I believe that Ferver, as the industry expert, should produce a paper (or possibly 2) called ‘best
practices in glass recycling’. This paper should examine 2 areaa:
1) Glass collection systems – here we should do a comprehensive study on different collection
systems e.g. mixed glass from igloos, kerbside comingled with other recyclable materials,
colour sorted from igloos, glass crushed at the producers site etc. We should look at each
collection system, and get real data on the experiences of collection companies throughout
Europe i.e. from our members. We should then report on data such as the yield from each
collection system (for example we know from our own experience that kerbside collections
result in approx. 25% more glass being collected, but of a much lower quality than bottle
bank), the CO2 advantages of one system over another etc, and the quality of the material
collected and ultimately how much of what is collected gets recycled into new glass. We
should then rank all of our findings to say for example (as I think we will find), that colour
sorted glass from igloos gives the best quality (e.g. as in Ireland), while mixed glass comingled
and treated in a MRF gives the worst quality (e.g. as in UK and Italy) with more of this
material being unrecyclable however it often results in more glass being collected. We
therefore present all of our findings to say which collection system is best and which is worst,
from different viewpoints e.g. environmental, economic etc.
2) Glass processing systems and end markets – again many different processes and uses for
glass exist. Of course Paolo and others will correctly argue that only glass which goes to
remelt to make new bottles is ‘real’ glass recycling. But we should not dismiss the practice by
some members in some countries of using glass in other markets such as fibre glass
insulation etc etc. Some of the countries involved also regard these uses as recycling, even if
for EOW we do not. Some simply crush all the material and use it in road construction for
example. However rather than just to dismiss these uses and say they are not really
recycling, we should look at all of the processes and markets, look at waste factors, uses and
final markets and determine the environmental benefits or otherwise of each type of system.
We can then say definitively for example, that using glass in glass manufacture saves 350kg
of CO2, while using it road construction can actually cause CO2, and so on for all the different
processes and markets.
I believe that such a paper will give governments, municipalities, companies and other interested
parties accurate data from a representative body (Ferver) in order to make informed decisions about
what types of glass collection and processing systems they will support and encourage and which
they will not and allow those of us that operate the ‘best’ systems to legitimately claim that we are
best in the class.
1
PAPER NR 2.
Recycling saves energy, reduces raw material extraction and combats climate
change. The vast majority of studies have found that recycling our rubbish is
better for the environment rather than incinerating or landfilling it.
Most households now have kerbside collections of recycling and the number of
different materials accepted is increasing. These materials can either be
separated at the roadside into different compartments in the lorry or collected
together and sorted afterwards.
It has been found that separating materials at the kerbside results in less
contamination of recyclables than mixed or ‘commingled’ systems. Cleaner
materials are more valuable to reprocessors and a higher proportion of these can
be recycled.
This briefing outlines the environmental and financial benefits of separating
materials at the kerbside.
Introduction
In recent years household recycling rates have risen dramatically. This has been
due in part to the Household Waste Recycling Act 2003, which Friends of the
Earth drafted and with our supporters. help got passed into law. This law means
that by 2010 English local authorities must collect at least two types of
recyclable waste from households.1 However, there are growing concerns in the
recycling sector about the systems being used to pick up materials
for recycling and the effect they are having on the quality of recyclables.
Local authorities operate two different systems to collect recycling:
*Source separation - materials are separated at the kerbside, usually into a
specially designed lorry with different compartments for different materials.
*commingled - materials are mixed together in a lorry which compacts the
materials. The recyclables are separated later, usually at a materials recycling
facility (MRF).
Defra advises local authorities that “source separation of materials is the first
step to maximising the value of recycling”, and notes that “the earlier in the
collection chain a recyclate is separated the lower the likely cost and
environmental impact of the collection scheme.”2
One of the UK.s largest waste management companies Biffa also argues that the
earlier materials are separated, the better the overall system and the lower the
2
likely environmental impact and cost.3 Their „Future Perfect. report states “The
householder is ideally placed to act in a way in which dry recyclables (and
organic materials) are kept out of the waste, reducing both contamination and
the quantity of residual waste for final disposal. This can capture a high level of
the available materials in a form which would be welcomed by many processors,
circumventing any need for MRFs, which tend to be both labour and capital
intensive.”But despite the evidence backing separated collections, many
councils are moving away from source separation to commingled systems.
Why is source separation better than commingling?
Advantages of source separation
.
source separation results in less contamination of recyclables and so a higher
proportion of them can be recycled.
.
stillage vehicles used for kerbside separation have lower fuel use than
compactor vehicles used for commingled systems
.
local bulking of sorted materials means lower mileages
.
increased revenue from sale of materials
.
lower capital costs and more local jobs
.
staff separating materials at the kerbside can give immediate feedback to
householders by leaving material which can.t be accepted for recycling with a
note, while still taking those materials which can be accepted.
.
kerbside separation of materials can easily cope with additional items – such as
batteries, textiles – by adding extra compartments into the vehicle. These would
be difficult or impossible to separate adequately in a MRF.
.
the total cost of collection and processing together are lower in source separated
systems than in commingled systems.4
Disadvantages of commingled collections
.
less of the material collected gets recycled (typically 12 – 15 per cent is wasted
in English MRFs,5 compared to less than 1 per cent for source separated
systems)
3
.
the risk of contamination makes it unsuitable to commingle some materials, for
example glass should not be mixed with textiles or paper
.
compaction can make it impossible to recycle some materials, particularly
aluminium, plastic and glass6
.
the trend in recyclate markets is likely to be towards requiring higher quality
materials. Lower quality commingled recyclables are currently being bought by
reprocessors in China. But in the future these processors will demand higher
quality materials.
.
increasing energy prices are likely to result in increased prices for recycled
materials, particularly those with high embodied energy – e.g. aluminium, steel,
glass, paper, plastic – which will shift the balance towards separate collection to
maintain quality.
Recycling helps reduce climate change
The way we treat our waste has large impacts on climate change. Most life cycle
assessment studies show that recycling offers more environmental benefits and
lower environmental impacts than other waste management options.7 Therefore
source separation is better for the environment because it results in less
contamination of recyclables, meaning a higher proportion can be recycled.
Recycling reduces the need for extraction and processing of new resources,
therefore saving fossil-fuel energy, and avoids the climate impacts of alternative
waste treatment
systems. These include the release of fossil-fuel derived carbon dioxide (CO2)
from incineration and the release of methane, a much stronger climate change
gas, from landfill.
Landfills release methane when biodegradable waste, such as food, garden waste
and paper is buried. Therefore biodegradable waste is one of the most important
parts to remove from the residual waste stream. Commingled collections cannot
include garden and food waste as these would cause too much contamination of
other recyclables and would be too difficult to separate. Both garden and food
waste should therefore be kept separate, unless households are able to compost
them at home.
Garden waste can then be treated by composting, which returns nutrients and
structure to soils, displaces other fertilizers and sequesters carbon. Food waste
4
can be composted in-vessel or anaerobically digested, which generates 100 per
cent renewable energy.
For more information please see the briefings „Food waste collections. at
www.foe.co.uk/resource/briefings/food_waste.pdf and „Anaerobic digestion. at
www.foe.co.uk/resource/briefings/anaerobic_digestion.pdf
Source separated systems have been found to have a lower overall impact on the
climate than commingled systems. When commingled collections replaced a
kerbside sorted system in the London Borough of Camden, an energy audit
found a 77 per cent increase in the overall carbon balance.8
Contamination of recyclables
WRAP commissioned a study on MRFs in the UK, US and EU. It found
contamination rates of up to 20 per cent, with English MRFs typically being at
the higher end.9 Some MRF managers reported that it is not cost effective for
them to reduce contamination. Kerbside sorting typically achieves much less
than 1 per cent contamination.
Where biodegradable materials rejected from MRFs are disposed of to landfill
they will release methane, a powerful greenhouse gas. Often, all the waste
delivered to MRFs is recorded as being recycled. However, Best Value
Performance Indicator (BVPI) guidance recommends that rejected materials
should be deducted from recycling figures.10 In future it is likely that any
rejected materials which are landfilled could count against local authority
Landfill Allowance Trading Scheme (LATS) allocations.
Quality of materials
Paper: Paper sorted from commingled collections is always contaminated with
other materials including glass, cans and plastic, and maybe even food waste.
Paper reprocessors therefore require separately collected paper in order to
maintain the quality of their product.
Some paper mills will not source recovered paper from MRFs or paper that has
been mixed with glass.11 Another consequence is that paper recycling will rely
on the export market, especially for paper collected with glass, and this market
could also become limited in the longer term.
Aluminium: Aluminium may be only 1 per cent of the weight of a kerbside box,
but perhaps 25 per cent of the value of materials. The aluminium reprocessing
5
industry prefers to recycle items into the same item again, for example drinks
cans are recycled into drinks cans. Aluminium foil uses a slightly different alloy
so will be reprocessed separately. High levels of Purity of aluminium are
required, especially for drinks cans. If aluminium products are
contaminated in a commingled system, they can only be used to create a much
lower grade of aluminium product. This means the price paid for the recycled
aluminium will be significantly reduced.
Glass: In order to re-melt glass into new containers, it requires a high level of
purity and to have been sorted by colour. Mixed or crushed glass, such as that
separated in MRFs, is of no use for re-melting and is usually sold much cheaper
for use as aggregate.
There is a big environmental benefit to recycling glass - each tonne of glass remelted in the UK saves 314kg CO2. However last year 280,000 tonnes of glass
collected for recycling was not suitable for re-melting.12 Unfortunately there is
no environmental benefit from using glass to make aggregate as it creates 2kg of
CO2 per tonne of glass collected.13 Therefore to be of benefit to the
environment, glass should be separated by colour as it is collected.
A very strong case can be made that recycling targets for both municipal waste
and packaging waste should be restructured to measure reduction in CO2 rather
than the current tonnage basis of targets – which is actually encouraging
collection of mixed glass for aggregate.
Plastics: Separately collected plastics have much higher value.
Material value
The value of materials is higher if separated at source than if sorted from
commingled waste.
A useful comparative study has been carried out by Bryson Recycling in
Northern Ireland.14 They receive recycled material from a number of districts
with a source separated box scheme, and from a number of districts with
commingled collections. They find the tonnage received per household is similar
for commingled and source separated at 127kg per year. The commingled
collection produces more paper but less aluminium, glass, steel cans,
plastic and textiles. The difference is mainly explained
bysignificancontamination of commingled paper with aluminium and plastic.
6
The result is they get £44 per tonne for commingled recyclables but £52 per
tonne for separately collected materials. That would be a difference of £400,000
per year on a throughput of 50,000 tonnes.
In November 2006 the following prices were reported:
.
separated PET plastic can be sold for £175 per tonne, but mixed plastic gets only
£40
.
clear glass gets £30 per tonne, but mixed glass only £12
.
white paper gets £170 per tonne, but mixed paper only £34
Collection and processing costs
The total cost of collection and processing together are lower in source separated
systems than in commingled systems. Although higher tonnages are collected
per shift in commingled systems, the compactor vehicles used have higher
capital cost, higher fuel cost, higher mileage to more remote MRFs, and there
are higher costs associated with separating The materials at the MRF.
Kerbside sorting requires much lower tech vehicles and lower fuel consumption
compared to commingled collections. It also requires much less capital
investment in local bulking depots and perhaps some low tech sorting (for
example to separate aluminium cans from steel) compared to using MRFs. The
main cost of kerbside sorting is local labour time.
A recent study by WRAP found that it is more cost-effective for councils to sort
recyclables at the kerbside than to collect them commingled, once the costs of
sorting at a materials recovery facility (MRF) are also taken into account.4
Other findings support this research. The case studies from Northern Ireland on
page 7 compare the costs for kerbside sorting and commingled collections. They
suggest that kerbside sorting provides a more cost-effective service, especially if
contamination losses are taken into account.
Another study of kerbside sorting costs for Newport Wastesavers estimated net
costs of approximately £61 per tonne for collection of kerbside sorted dry
recyclables. Assuming that £60 per tonne is a typical net cost of a kerbside
sorted collection, for a commingled
collection to compete on cost, the cost of commingled collection plus the gate
fee for a MRF would have to be below this.
7
The cost of collecting a tonne of commingled processed at a MRF has been
found to be higher than the £60 cost of sorting a tonne of recycling at the
kerbside. The cost only falls below £60 per tonne if the MRF runs two shifts
each day and processes over 40,000 tonnes each year. The cost falls to around
£40 per tonne if 85,000 tonnes are processed each year.17 A supply of 85,000
tonnes of recycling would require a population catchment of around 1 million
people. In most cases this would mean very long transfer distances.
Public support
If materials are separated at the kerbside people are more confident that they
will be recycled efficiently. They are therefore more likely to recycle their
rubbish.
Some evidence suggests that the tonnages of waste actually recycled from
commingled systems are less than from source separated collections. Box
schemes eventually overtake commingled collections once people get used to
them.
The Northern Ireland example on page 7 suggests that separate collection gets
more recyclables.
Case study –‘SORT IT!’ scheme in Somerset
Somerset Waste Partnership rolled out a weekly kerbside sorted collection of
dry recyclables in three districts over two years from October 2004, covering
155,000 households in Mendip, South Somerset and Taunton Deane.
Recyclables are collected in a 55 litre box and sorted into separate containers in
a 12 tonne vehicle. Vehicles cover 650 – 700 houses per day in urban areas and
500 in most rural areas. Food waste is collected by the same vehicle from 25
litre lockable bins.
Dry recyclables collected include paper, glass bottles and jars, food and drinks
cans, foil, textiles, shoes, and car batteries. Cardboard and plastic are not
currently collected, but can be recycled at Household Waste Recycling Centres.
If people put out waste which cannot be Recycled it is left with a sticker to give
instant feedback.
Rubbish which cannot be recycled is collected fortnightly, which is acceptable
to residents as food waste is collected separately. Compaction vehicles are used,
8
with a standard 140 litre wheelie bin, though people can ask for a smaller or
larger bin. There is also a paid-for fortnightly collection of garden waste in
compaction vehicles. A wheelie bin costs £15-£25 per year and compostable
sacks cost £5-£7.50 for 10. Charging for collection encourages home
composting and keeps down costs.
By collecting garden waste separately from food waste, it can be treated more
cheaply by
open-windrow composting. The food waste is mixed with 50 per cent green
waste and in-vessel composted to comply with the Animal By-Product
Regulations 2003.
In August 2006 the overall recycling rate was 39-47 per cent. It was estimated
that the collections were on average, per household per year, 165kg dry
recyclables, 90kg food waste and around 340kg residual waste.
The 90kg food waste collected per household per year compares to an estimated
200kg food in the waste stream before the food collection was added. It seems
that people are now throwing out less food waste overall – either because the
food collection is making them think more carefully about waste, or because
people are composting more at home. Total waste arisings appear to have
dropped by around 150kg per household per year initially.
Total collection costs have been estimated for Taunton Deane at £45.52 per
household, or £39.99 net of recycling credits. This excludes disposal costs which
will include landfill gate fee and landfill tax. Per tonne of recycled and food
waste, the cost is £107.08 for collection, or £86.40 net of credits. The residual
and garden waste together costs £40.07 per tonne for collection.
The SORT IT! collections have been rolled out in batches of 12,000 – 16,000
houses with carefully targeted public information. Follow-up questionnaires
suggest 76 per cent of residents say the service is better than previously, and 87
per cent say it is easy to separate waste into the required categories. 79 per cent
say one of the top benefits is more recyclingand composting, and 72 per cent
welcome weekly recycling.
Somerset.s SORT IT! collections won the Best Local Authority Initiative at the
National Recycling Awards 2005 and the Local Authority Award at the 2005
Annual Composting Association Awards. Visits from other local authorities are
welcomed. Details are available from David Mansell at Somerset County
Council on 01823 356013 or
dgmansell@somerset.gov.uk.
9
Case study – comparison of costs for kerbside sorting
and commingled bins in Northern Ireland In 2006, WRAP published two reports
by ENTEC on behalf of ROTATE (the local authority recycling advisory
service) reviewing the collection services in Castlereagh18 and Belfast.19
Both compared the costs of extending a kerbside sorted box collection or a
commingled bin collection to the whole of the district.
Castlereagh
Part of Castlereagh was already served by a box sorted at the kerbside and part
by a commingled „blue bin.. Both areas had a residual waste collection and a
separate green waste collection. The study compared the costs and benefits of
rolling out each option to all 27,500 households in the borough.
It found that the lowest cost per tonne recycled would be achieved by the
kerbside box. The next lowest would be for the commingled bin plus separate
glass collection. The commingled bin would cost more to set up in the first year
but less in subsequent years, and would collect less recyclable material.
If each service were provided to 27,500 households together with a separate
green waste collection, the kerbside box system would collect 281kg per
household per year for recycling/composting compared to 214kg for the
commingled bin. These figures are based on established performance for each
scheme. The commingled bin collection could be improved to 260kg by
collecting glass as an additional separate collection, which would nearly pay for
itself.
Moving all of the households to a kerbside box system would be £200,000
cheaper than the commingled bin plus glass collection to set up in year one, but
£111,000 per year more to run after that. The total cost of collection and
disposal per household would be:
.
for the kerbside box option, £59.85 in the first year, then £54.73 per year.
.
for the commingled bin plus glass option, £67.13 in the first year, then £50.69
per year.
It should be noted that these costings do not include depreciation costs on
vehicles, which would add more cost to the commingled bin option as it uses
more expensive compaction vehicles.
10
The report also found that residents were reasonably happy with both existing
services, so suggested that in the short term the disruption which would be
caused by moving to one system was not advisable. In the longer term, it noted
that as the costs of residual waste disposal will increase so there will be a need
to maximise kerbside recycling yields as well as to promote waste minimisation.
It was recommended that the performance of the two systems be further
monitored before making a final decision.
Belfast
The Belfast study compared the costs associated with moving to a fortnightly
residual waste collection together with a fortnightly recycling collection by
either a kerbside „black box. or a commingled „blue bin. for 50,000 households.
It found that the kerbside sorted box would incur a one-off net cost of £174,000
in the first year but net savings of £183,000 per year after that. The commingled
bin would incur a net cost of £522,000 in the first year and net increased costs of
£188,000 per year after that. Both would have similar rates of recycling and
avoided landfill costs.
The main reasons for the higher costs of the commingled bin (over £340,000 per
year higher) were the higher vehicle costs for commingled bin and the lower
marginal costs of expanding the box system.
The preferred option was therefore a fortnightly kerbside sorted box system,
provided that it was supported by work to inform residents and gain their
support for the box system. It was also recommended that a food waste
collection be considered to improve acceptance of a fortnightly residual
collection.
Case study – Mersea Trial
In 2000, a number of trials were started in Essex to test the feasibility of
reaching a 60 per cent recycling and composting rate for household waste. One
covered 4,500 households in Mersea which already had a good record in
recycling.
The results for Mersea showed that in 2001, 56 per cent of household waste was
being collected for recycling or composting. This included collection at Civic
Amenity (CA) sites 5excluding rubble and soil). The total cost of collection,
including the CA sites, was £56.54 per household, or about £50 per tonne. This
is in a fairly rural area.
11
The collection from households used four different vehicles visiting each house
weekly on the same day:
.
A large basketback truck collecting paper and card at one end and plastic at the
other .
A Fame. flatback truck with stillages for glass colour-sorted at the kerbside, and
cans sorted and baled locally to separate aluminium and steel .
A compactor truck for green waste, collected in re-usable sacks .
A compactor truck for residual waste, collected in black bags
The trial was monitored by Enviros Aspinwalls, which reported 82 per cent
participation and 98 per cent public satisfaction. They estimated capture rates
(including CA sites and bring sites), per household per year, as:
.
Green waste - 358kg collected out of 360kg available
.
Glass and cans - 78 collected out of 201kg available
.
Paper and card - 176kg collected out of 319kg available
.
Plastic bottles - 11kg collected out of 15kg available
.
Textiles - 3kg collected out of 17kg available
By autumn 2002 Colchester.s Recycling Officer reported that the trial had
reached 60 per cent recycling at a cost of £53 per household. Costs could
probably have been cut further as the scheme developed.
However, instead of rolling out the Mersea trial across the Borough, collections
in split compactor vehicles were introduced. These could not cope with all the
separated materials now being collected, resulting in some recyclables being
collected with residual waste, as well as a huge overspend. Consultants have
recommended buying back some of the former vehicles.
Conclusion
In Friends of the Earth.s view separate collection is the best system for domestic
waste collection. We have therefore joined with recyclate reprocessors
12
(including glass, paper, aluminium and textile) and community recycling groups
to form the Campaign for Real Recycling (CRR).
This campaign promotes source separated collections through highlighting the
financial and environmental advantages. It also explores the considerable
potential in the UK for development of a secondary materials economy. More
information can be found at www.realrecycling.org.uk/
This briefing was written by Becky Slater based on research by Nigel Lee.
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Further reading
Recycling – why its important and how to do it
www.foe.co.uk/resource/briefings/recycling.pdf
.
Food waste collections
www.foe.co.uk/resource/briefings/food_waste.pdf
.
WRAP's leaflet „Choosing the right recycling collection system' says that source
separated kerbside collections are the "best and cheapest option in most cases"
www.wrap.org.uk/downloads/Choosing_the_right_recycling_collection_system.
e484c98f.7179.pdf
1 Household Waste Recycling Act 2003,
www.opsi.gov.uk/acts/acts2003/20030029.htm
2 DEFRA (2005), “Guidance for Waste Collection Authorities on the Household
Waste Recycling Act
2003”, www.defra.gov.uk/ENVIRONMENT/waste/legislation/hwra/hwraguidance.pdf (pp8&20)
3 Biffa (2002), “Future Perfect”, p63.,
www.biffa.co.uk/content.php?name=publications/futureperfect.html
4 WRAP (2008), “Kerbside recycling: indicative costs and performance”,
www.wrap.org.uk/downloads/Kerbside_collection_report_160608.41243a68.55
04.pdf
5 Dougherty Group LLC for WRAP (2006), “Materials Recovery Facilities”,
p43,
www.wrap.org.uk/document.rm?id=3528
13
6 ENTEC Consulting for WRAP (2006), “MRF Costing Model”, Bob Graham,
p21, www.wrap.org.uk/document.rm?id=3529
7 WRAP (2006), “Environmental benefits of recycling: An international review
of life cycle comparisons
for key materials in the UK recycling sector”,
www.wrap.org.uk/wrap_corporate/about_wrap/environmental.html
8 ADAS UK Ltd (2008), “Energy Audit of the Kerbside Recycling Services”
http://82.196.227.114/RemoteStorage/camden/Releases/346/Energy%20Audit%
20Camden%20Report%202%207.doc
9 Dougherty Group LLC for WRAP (2006), “Materials Recovery Facilities”,
p43, www.wrap.org.uk/document.rm?id=3528
10 Dougherty Group LLC for WRAP (2006), “Materials Recovery Facilities”,
p57, www.wrap.org.uk/document.rm?id=3528
11 ENTEC Consulting for WRAP (2006), “MRF Costing Model”, Bob Graham,
www.wrap.org.uk/document.rm?id=3529
12 Statement by Berryman Glass, the UK.s largest recycler of waste glass,
March 2007
13 Enviros Consulting Ltd (2003), “Glass Recycling: Life Cycle Carbon
Dioxide Emission”,
www.britglass.org.uk//Files/LocalAuthorities/BGEnviroReport.pdf
14 Bryson Recycling (2006), Presentation to WRAP seminar on MRFs, Eric
Randall, www.wrap.org.uk/wrap_corporate/about_wrap/mrf_conference.html
15 WRAP (2006), MRF Conference 9 November 2006,
www.wrap.org.uk/wrap_corporate/about_wrap/mrf_conference.html
16 Deloitte for Wales Audit Office/Swyddfa Archwilio Cymru (2006), “Report
on the Performance of
Newport Wastesavers. Kerbside Collection of Dry Recyclables”, November
2006.
17 ENTEC Consulting for WRAP (2006), “MRF Costing Model”, Bob Graham,
p51, www.wrap.org.uk/document.rm?id=3529
18 Entec UK Ltd on behalf of ROTATE (2006), “Castlereagh Service Review A report to Castlereagh Borough Council”
19 Entec UK Ltd on behalf of ROTATE (2006), “Review of Kerbside
Collection Schemes - A report to Belfast City Council”
14
PAPER NR 3
Evening Ulrich,
Here some small answers:
1)
2)
Both Paper and plastics processors are aware of the situation and are able to deal with it. OFF course
in the ideal world they would like to leave it out of the material (higher maintenance costs) but
knowing that 3 papermills in the UK have built a sorting facility (Material recycling Facility) to process
and sort Comingle we know they have made now a clear point they will work with it and deal with it.
About the plastics industry it is the same, we as Viridor have ourselves a bottle plant and are able to
process Mixed bottles (plastics) what contains a percentage of glass (1-2%). It has become very
normal and common also because the whole industry have invested being able to process comingled
recyclables (worked with the data given, stated and provided by DEFRA)
I totally agree with this as Viridor is looking and investigation, as we speak, to build 2 plants able to
process glass cullet’s coming out of the comingled streams (MRF’s). Knowing several glass customers
already discussed this possibility with us we know this is the future and we need to be ahead of the
market. We DO see that it is more the plastics percentage what is increasing in the comingled
(different polymers) and we know that plastics is easier to sort out the comingle than metals, paper
and glass.
For me it is not if I support or not, I am afraid it is a process neither of us can change anymore, certainly when
I am getting more and more noises back from the continent that councils are investigating also the collections
of comingled streams, pure and solely because of the reduction in costs (Described also in a WRAP report about
a year ago, backed up by DEFRA).
Hope I have given you a slighter better view on the UK comingle market.
Kind regards
Viridor
Herman van der Meij
Director VRM
From: Ix, Ulrich [mailto:Ulrich.Ix@dkr.de]
Sent: Wednesday, June 29, 2011 8:54 AM
To: Herman Van Der Meij
Cc: Mick Keogh; Matthew Demmon; Raf Vanswartenbrouck; Pieter Bartels; Hans De Belder;
Baudouin Ska
Subject: AW: co-mingled of separated
Good morning Herman,
thanks for the article.
Two remarks :
a) Plastic and paper secondary raw material is allergic to glass impurities. One
cullet and even fines can seriously damage the production lines. In the past
we several times tried to sell the plastic bottles we get today with the glass
collection to various plastic producing companies. They all refused for this
reason.
How about the reaction of plastic and paper companies about commingled
collection in UK? Is there any? What is your experience?
b) Although commingled collection will definitely increase the contents of
parasitical waste (if the consumer can throw in more than one fraction he will
throw in a lot more) and this kind of system finally cannot be avoided in future I
believe it is a chance for glass recyclers to increase their business : This
15
mixture of various materials containing glass can only be separated by a glass
recycling plants. Plastic- or paper recycling plants are not able to handle glass.
To make it very clear : I'm absolutely not supporting commingled collection.
But we should be prepared and have to look at it from different points of view.
With best regards
Ulli
,
Von: Herman Van Der Meij [mailto:HVanDerMeij@viridor.co.uk]
Gesendet: Dienstag, 28. Juni 2011 19:57
An: Pieter Bartels; Hans De Belder; 'Baudouin Ska'
Cc: Mick Keogh; Matthew Demmon; Raf Vanswartenbrouck; Ix, Ulrich
Betreff: RE: co-mingled of separated
Maybe good to know DEFRA’s point:
Commingled boost as WFD regulations
are laid
8 February 2011
By Nick Mann
Defra has confirmed that commingled recycling will count towards the
"separate" collections of material required by the revised Waste Framework
Directive after 2015.
The confirmation came in a letter sent to stakeholders by the department informing
them draft regulations for implementing the legislation in England and Wales had
been laid before Parliament today (February 8).
Defra acknowledged in November that
there were industry concerns that it had
"fudged" the wording of the revised
Waste Framework Directive (rWFD)
and that some believed "there was no
explicit approval in the Directive for
commingled collections".
In particular, concerns were raised that
allowing commingled to count towards
the goal would work against the
requirement also made by Article 11(1) of the Directive for the government to
encourage "high quality" recycling, and also that it was inconsistent with the
Directive's requirement that defined waste materials be kept separately.
16
Now, in the letter sent today, Defra makes it clear that in England and Wales both
commingled and source-separated recycling will be regarded as acceptable under
Article 11(1) of the Directive, which expects separate collection of at least paper,
glass, metal and plastics by 2015.
The letter, which relates to the draft ‘Waste (England and Wales) Regulations 2011',
states: "In line with the stage two consultation proposals, the draft Regulations provide
that "co-mingled collection" (i.e. the collection together of waste paper, metal, plastic
and glass but separately from the collection of other types of non-recyclable waste) is
a valid form of "separate collection" for the purposes of the Regulations transposing
the rWFD."
"The wording of the draft Regulations on this point has been amended since the stage
two consultation to add clarity," it adds.
Defra's position is likely to differ slightly from the Welsh Assembly Government
which, as was alluded to in the July 2010 consultation on transposing the rWFD,
stated a preference for kerbside sorted recycling in its 2010 waste strategy (see
letsrecycle.com story).
Recycling targets
While the full text of the draft regulations is yet to be made publicly available, the
letter also provides detail on how the regulations interpret some other key aspects of
the rWFD, and in particular its target for 50% of household waste to be collected for
recycling and reuse by 2020.
Defra explains in the letter that the European Commission's rules for defining how the
targets will be complied with are set to be considered by the UK and other EU
member states this spring, and will require European Parliament scrutiny before
coming into force.
But, it confirms that the Commission's current position is that, while household waste
- defined as "waste generated by households" that is prepared for reuse will be
included in the amount of waste recycled, it will not have to be reported separately.
"The Commission have proposed that the amount of waste prepared for re-use should
be included in the amount of recycled waste and there would not be a requirement to
report the former separately," the department states in the letter.
This is likely to disappoint third sector and community groups involved in the reuse
sector, who have long championed more specific requirements for reuse to encourage
reuse above recycling.
Waste hierarchy
The WFD is underpinned by the new five-step waste hierarchy being implemented as
a legal requirement on all waste management and policy decisions, but Defra's letter
reveals that, to ensure the "effective implementation" of the hierarchy, the draft
regulations allow a six month transition period before this requirement comes into
17
force.The letter explains that the key ways the hierarchy will be applied in England
and Wales are:




Updating national planning policy to reflect it, requiring councils to regard it in
preparing waste development frameworks and regional waste plans;
Requiring the Environment Agency and councils to include a condition in new
and revised waste permits for the holder to minimise waste and treat it
according to the hierarchy;
Amending the ‘duty of care' to add a declaration to waste transfer notes
confirming the hierarchy had been taken into account when dealing with waste;
Requiring councils and businesses, as part of their duty of care, to follow
government guidance on applying the hierarchy, including when to deviate
from it to achieve a better environmental outcome.
Parliament/ Related links /Defra - revised Waste Framework Directive
The draft regulations are now subject to debate and approval in both Houses of
Parliament before coming into force, and must similarly be debated and approved by
the National Assembly for Wales
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
From: Pieter Bartels [mailto:Pieter.Bartels@maltha.nl]
Sent: Tuesday, June 28, 2011 3:20 PM
To: Hans De Belder; 'Baudouin Ska'
Cc: Mick Keogh; Matthew Demmon; Herman Van Der Meij; Pieter Bartels; Raf
Vanswartenbrouck; Ix, Ulrich
Subject: co-mingled of separated
Dear Hans / Baudoin
See attached document
Did start looking to co – mingled and to separate collection and already found this
article There must be more
Discussed item with Hans that we should take this item in the steerting cotttee
So plse do and start looking whether indeed correct that UK allowed to have co –
mingled to be seen as separate collection or something like this
Regards
Pieter bartels
PAPER N4 END OF WASTE FINAL REPORT
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
18