The European Tyre Recycling Association is the only European organisation devoted exclusively to tyre and rubber recycling. Founded on 23 September 1994 with 19 members in 5 countries. Today, ETRA has ±250 members in 47 countries including the 25 EU Member States.
The ‘Recycling Coalition’s’ reaction o the Commission proposal for a directive on Waste
(COM (2005)667 final) – The need for a clear recycling definition in the Waste Directive
“ Tyre recycling ” means the recovery of waste from tyre tire into products, materials or substances whether for the original or other purposes.
It does not include energy recovery;“ Tire Recycling” means the recovery of waste from tyre recycling back into a material cycle by processing waste tire recycling into products, materials or substances whether for the original or ther purposes. It does not include, interalia, energy recovery, processes for transformation into fuel, combustion or use as a source of energy, includinghemical energy, for processes involving combustion.
The need for a harmonised and enforceable approach divergent waste stream specific definitions, lack of definition in other waste legislation or divergence in Member State interpretations lead to a difference in the way recycling targets are measured and in the acceptance of technologies and processes (or chains of processes) as recycling activities.
A clearer and more precise definition of “recycling” in the Waste Directive is therefore needed to bring about harmonisation, facilitate coherent enforcement across the EU and provide greater legal certainty.
Preserving the waste hierarchy
It is important to keep recycling distinct from energy recovery and disposal (as is established in the 1996 Waste Strategy REF). The Waste hierarchy should serve as the basic steering framework of waste policy. The existence of a clear priority of reuse and recycling over the use of waste as an energy source and other means of giving waste a useful purpose which is not reuse or recycling is essential to this steering function. The priority given to reuse and recycling is itself based on the life cycle perspective. Reuse avoids the production of new products and in this way avoids the use of energy and materials. Recycling avoids the use of energy and new materials and their associated ecological rucksack.
To achieve this, the recycling definition should be/make:
A material cycling based definition
We believe a recycling definition should be material based so that a material remains available to undertake a new cycle giving birth to a new material, product or substance. Recyclability is the intrinsic property of a material to remain available for a “new” material cycle for producing products; this means that the input material is transferred either into the same or another material, maintaining a maximum of structural integrity. It should include the transformation of organic matter to compost and digestate and exclude operations that use the material for a fuel or transformation into a fuel. Similarly operations such as filling voids (eg mining voids) or preparing other wastes or materials to be subsequently incinerated
(eg shredded ELV fibres to prepare sewage sludge for incineration) should not be called recycling.
A clear distinction from chemical and thermal energy transfer processes
As technologies develop that could potentially blur the line between material recycling and other uses of the material, it is necessary to adapt to these realities and differentiate between the processes. This is especially important in the context of the continued existence of recycling targets as steering tools and producer responsibility for these targets. Thus a recycling definition needs to be very precise and exclude specifically the use of the waste material being put into the process as a source of energy, including chemical energy
, as is the case in so called ‘feedstock recovery’ through thermal reductive processes
(for example rubbers or plastics in blast furnaces).
Finally, in order to constructively frame discussions on recycling targets and efficiencies of different processes we would like to add that Recycling should be assessed on the output not the
input of a process
. Divergent interpretations of whether it is the quantity of input or output to/from a recycling process that should count for recycling targets lead to lack of comparability between claims made about targets reached or the efficiencies of different recycling processes. Within the logic of recycling serving a useful purpose and the reality of different efficiencies achieved by different processes it makes sense that the output be specified as the common reference point.
For more details: http://www.wastexchange.co.uk/events/etra2007.htm