Once Germany’s energy transition (i.e. changing its energy supply from fossils to renewables) really got going, it soon became very clear that the country’s climate goals could not be reached simply by installing wind turbines and solar cells. Too much energy was being wasted as a result of heat escaping through poorly insulated walls. This led to an initiative being introduced to have as many outer walls as possible insulated with composite insulation boards made of pre-treated polystyrene. Now, many years later, the first of these buildings are being renovated. And yet, within a very short space of time, a change in the law to adopt European waste legislation has turned this material – previously classified as unproblematic mixed construction waste – into hazardous waste. It was almost impossible to find the transport needed to remove the material at such short notice; suitable storage space was nowhere to be found. The result: this waste began piling up at the construction companies. REMONDIS also received many calls from such businesses asking for help.
In the past, insulation material treated with hexabromocyclododecane (HBCDD) – not to be confused with harmless polystyrene packaging – did not need to be collected separately from other types of waste. It fell into the category of ‘mixed construction waste’ and could be thrown into the skips at the building sites with the other types of construction waste. The Commission Regulation (EU) 2016/460 of 30.03.2016 amending Annexes IV and V to the POPs regulation came into force on 30.09.2016. HBCDD with a concentration limit of 1,000 mg/kg has been added to the list which means that it is now considered to be hazardous waste in Germany (as stipulated in the German Waste Catalogue Ordinance) and must be collected separately. Austria, however, has shown that such changes to the law are actually not necessary. There, the material may continue to be incinerated in waste incineration plants together with non-hazardous waste. The country had previously carried out large-scale tests that proved that co-incinerating polystyrene containing HBCDD did not have a negative impact on the environment whatsoever. The flame retardant HBCDD was completely destroyed. HBCDD was used as a flame retardant by the insulation industry for many years and is in practically all of the insulation materials currently found in buildings across the country. The fact that this material has such a high calorific value also means that incineration plants are unable to treat it in ‘mono-batches’ – further aggravating the problem of how to dispose of it.
Insulation material treated with HBCDD has been on the list of hazardous waste since 30.09.2016
REMONDIS has been standing by its customers and is holding intensive discussions with the authorities and ministries to find a solution to this problem as quickly as possible. This change to the law, however, has meant that it has not always been possible to collect all of this waste material. In the meantime, the states have passed their own individual regulations to relieve the current unsatisfactory situation.
The current bottlenecks at the incineration plants have made it even more difficult to incinerate treated insulation material.
This problem has not been caused by the recycling industry but by a change to the German Waste Catalogue Ordinance passed by the Bundesrat (upper house of the German parliament). The Federal Ministry for the Environment had informed the upper house – which comprises representatives of all German states – well in advance that this decision would lead to waste disposal ‘bottlenecks’. These warnings were ignored. The current situation has eased a bit as a result of the states passing their own regulations. It is, however, essential that the legislator comes up with a single solution that is valid for the whole the country – a solution that is similar to that in Austria that lowers the hazard level and allows it to be incinerated with other types of waste. The recycling sector is assuming that this will lead to a compromise that is acceptable for all Federal states and thus ensure there is once again a trouble-free system in place to collect and treat this material.