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  • Dear Readers!

    Many people in Europe could hardly believe the news when they woke up on 24 June to discover a slim majority of Britons had voted in favour of Brexit. Leading economists, politicians, business people, artists and scientists had repeatedly called for the UK to remain in the EU so that the problems of globalisation could be tackled together as one strong community. Their words were in vain; the majority of Britons decided that the best way forward was to take a step back towards the sup­posedly good old days of 'splendid isolation'. No-one at that time, however, could have anticipated that this was just a precursor of an even bigger political earthquake. On 08.11. American voters elected Donald Trump to be their next president. Never before had the country experienced such a populist movement and his comments do not bode well either for the global economy or for a peaceful co-existence between nations. Only time will tell whether or to what extent President Trump will try and change global economic and political structures. Only then will we be able to see what impact this will all have on Europe. However, no matter how much the new President tries to deny the very existence of climate change, there is one thing that is clear right now: the world’s population will continue to grow and the challenges of meeting people’s needs and tackling the planet’s environmental problems will not become easier in the future. Our recommendation to Donald Trump, therefore, would be to take a look at the country of his ancestors – at Germany, where solutions are already being developed to create a sustainable supply of raw materials for the future.  

    Over 40 years ago, when the recycling sector was just beginning to find its feet in Germany (thanks also to the many contributions made by REMONDIS), there were approx. 3.5 billion people living on our planet. At that time, recycling was considered by many to be nothing more than a bit of a gimmick. The world had enough raw materials and plenty of space for storing waste – so why do more than we have to? The human race needed just under 100,000 years to reach 3.5 billion people. This figure has doubled within just 40 years! By 2050, it is expected to rise to 10 billion. The so-called Earth Overshoot Day, the date when humanity has exhausted nature’s budget for the year, was even earlier this year: on 08 August. Since then, we have effectively been living as if we have a second planet to fall back on.

    The recycling sector already offers solutions to these problems at a number of different levels: supplying raw materials, generating energy, protecting water supplies and the environment, curbing global warming and even taking on social responsibilities. 14% of the raw materials used in Germany are supplied by the recycling industry, an important step to separating economic growth and the consumption of natural resources from one another. If our production processes are to be sustainable and affordable in the future, then all products and raw materials must be recovered and reused. For this to be possible, however, politicians around the world must drive this development and introduce ambitious laws to ensure it happens. We need higher recycling targets and mandatory ecodesign guidelines that force manufacturers to design their products so that they can be fully recycled once they reach the end of their useful life.

    Recycling would be become mandatory in a future where all raw materials and products – no matter whether it be a smartphone, car or plane – must be designed in line with ecological criteria. Children working in mines in third world countries would be a thing of the past. Wars would no longer be fought to gain access to natural resources. Innovative processes would mean that our wastewater could be used to produce clean drinking water and as a source of phosphorus for fertilisers, building supplies and energy. Collecting and recycling organic waste around the globe and turning it into high quality compost or using it to generate renewable energy would, for the most part, solve the problem of climate change – and also provide great prospects for growth.

    With this optimistic look into the future, may I wish you and your families a very happy, healthy and prosperous New Year.

    Ludger Rethmann

The difficulty of disposing of insulation

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.

New ordinance open to doubt

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 is pushing for a solution

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.

  • An overview of these special regulations can be found here (German only)

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