INTRODUCTION TO EU
LEGISLATION RELATED TO
HBCDD AND POP-BDES
TAIEX Workshop on Persistent Organic Pollutants Waste
Management
Martien Janssen (NL), Timo Seppälä (FI)
Bratislava, 21 April, 2016
CONTENTS
Introduction to POP Regulation (EU) 850/2004
| BDE provisions
| HBCDD provisions
| Other legislation related POPs waste management
|
POP REGULATION
Implements Stockholm Convention and UNECE/LRTAP
POPs Protocol in the EU
| Legally binding to all Member States (MS) as such
| Annexes have been updated since 2004
|
Including new POPs
y Setting waste limit values
y
POP REGULATION STRUCTURE- 1
|
Article 1 - Objective and scope
|
Article 2 - Definitions
|
Article 3 - Control of production, placing on
use
|
Article 4 - Exemptions from control measures
|
Article 5 - Stockpiles
|
Article 6 - Release reduction, minimisation and elimination
|
Article 7 - Waste management
|
Article 8 - Implementation plans
|
Article 9 - Monitoring
|
Article 10 - Information exchange
|
Article 11 - Technical assistance
|
Article 12 - Reporting
|
Article 13 - Penalties
the market and
POP REGULATION STRUCTURE- 2
|
Article 14 - Amendment of Annexes
|
Article 15 - Competent authorities
|
Article 16 - Committee for general matters
|
Article 17 - Committee for waste matters
|
Article 18 - Amendments to Directive 79/117/EEC
|
Article 19 - Entry into force
|
This Regulation shall enter into force on the twentieth day following that of
its publication in the Official Journal of the European Union.
|
This Regulation shall be binding in its entirety and directly applicable in all
Member States.
ARTICLE 3 - CONTROL OF PRODUCTION,
PLACING ON THE MARKET AND USE
|
1. The production, placing on the market and use of substances listed in
Annex I, whether on their own, in preparations or as constituents of articles,
shall be prohibited.
|
2. The production, placing on the market and use of substances listed in
Annex II, whether on their own, in preparations or as constituents of
articles, shall be restricted in accordance with the conditions set out in that
Annex.
|
3. Member States and the Commission shall, within the assessment and
authorisation schemes for existing and new chemicals and pesticides under
the relevant Community legislation, take into consideration the criteria set
out in paragraph 1 of Annex D to the Convention and take appropriate
measures to control existing chemicals and pesticides and prevent the
production, placing on the market and use of new chemicals and pesticides,
which exhibit characteristics of persistent organic pollutants.
POP REGULATION LIMIT VALUES
|
Regulation sets several limit values
1.
Unintentional Trace Contaminant (UTC)
|
2.
Specific limits
|
3.
Defines the level that is considered outside the scope of the
regulation
When UTC is not feasible
Waste limit values
Low POP-content level for waste (LPCL, Annex IV)
| Defines the limit above which waste is considered POPs waste
| Upper POP-content level for waste (HPCL, Annex V)
| Defines the level at which further restriction for waste
management kick in
|
UNINTENTIONAL TRACE
CONTAMINANT
|
The European POP regulation refers to the unintentional trace contaminant
in article 4.1.b.
y
A substance is considered to be an unintentional trace contaminant if it is present
in quantities equal to or below a fixed threshold set in the POPs Regulation. The
thresholds were set to correspond to a level below which the substance cannot be
meaningfully used and above detection limit of existing detection methods to
enable control and enforcement.
y
Currently unintentional trace contaminant contents are only set for the four POPBDEs, HCBDD and for PFOS
|
y
y
See Annex I of the EU POP Regulation.
Stockholm Convention Annex A:
"Except as otherwise specified in this Convention, quantities of a chemical occurring
as unintentional trace contaminants in products and articles shall not be considered to
be listed in this Annex;".
There is a UNEP/POP document in which the data on unintentional trace contaminants
have been compiled: UNEP-POPS-COP.5-INF-10.English.
SPECIFIC LIMITS
|
C. Specific limits have been set for certain processes or products, because
implementation of the unintentional trace contaminant is not feasible.
|
The limits are provided in Annex I of the EU POP Regulation for the four
POP-BDEs, PFOS and SCCPs.
|
The POP-BDEs have these specific limits for recycling (0.1% compared to
the 0.001% unintentional trace content). These specific limits always start
with the words "By way of derogation the production, placing on the market
and use of the following shall be allowed..."
y
The limits for the POP-BDEs are an implementation of the recycling clause in annex II of
the convention.
LOWER AND UPPER WASTE LIMIT
VALUES
|
Low Pop Content on waste.
y
This low POP content is regulated in Annex IV of the EU POP Regulation (column 4
contains the values) and is referred to in article 7.4a.
y
If the concentration of a POP in a waste exceeds the low POP content, the waste
has to be treated in a way that the POP is destroyed or irreversibly transformed
so that it does not display any POP characteristics.
y
Above this limit, waste is considered as POP waste.
|
|
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See also article 6.2.c of the Convention which handles on waste.
See also the Basel guidelines for further information.
Upper limit value for POP content on waste
y
y
Higher POP-content limit value is regulated in Annex V, part II
Above this limit, alternative disposal options (Art 7.4(b) cannot be used
ARTICLE 3 – LISTING OF POP-BDES
|
Initial nomination to SC: commercial octabromodiphenyl ether and
commercial pentabromodiphenyl ether
|
Cannot be listed as such
y
y
y
Commercial mixtures of varying constitution
Commercial mixtures can not be measured, only pure substances can
Which constituents have POP characteristics?
ARTICLE 3 – LISTING OF POP-BDES
|
Initial nomination: commercial octabromodiphenyl ether and
commercial pentabromodiphenyl ether
|
For the purpose of this Annex:
(a) “Hexabromodiphenyl ether and heptabromodiphenyl ether” means 2,2',4,4',5,5'hexabromodiphenyl ether (BDE-153, CAS No: 68631-49-2), 2,2',4,4',5,6'hexabromodiphenyl ether (BDE-154, CAS No: 207122-15-4), 2,2',3,3',4,5',6heptabromodiphenyl ether (BDE175, CAS No: 446255-22-7), 2,2',3,4,4',5',6heptabromodiphenyl ether (BDE-183, CAS No: 207122-16-5) and other hexa- and
heptabromodiphenyl ethers present in commercial octabromodiphenyl ether.
(b) “Tetrabromodiphenyl ether and pentabromodiphenyl ether” means 2,2',4,4'tetrabromodiphenyl ether (BDE-47, CAS No: 5436-43-1) and 2,2',4,4',5pentabromodiphenyl ether (BDE-99, CAS No: 60348-60-9) and other tetra- and
pentabromodiphenyl ethers present in commercial pentabromodiphenyl ether.
ARTICLE 3 – COMPOSITION OF
COMMERCIAL BDE MIXTURES
ARTICLE 3 – POP-BDES IN ANNEX I
ARTICLE 3 – LISTING OF HBCDD
|
‘Hexabromocyclododecane “Hexabromocyclododecane” means:
hexabromocyclododecane, 1,2,5,6,9,10-hexabromocyclododecane and its
main diastereoisomers: alpha- hexabromocyclododecane; betahexabromocyclododecane; and gamma-hexabromocyclododecane
y
Exemption in the Stockholm Convention:
Use in buildings of expanded polystyrene articles and extruded polystyrene articles
|
|
y
Time-limited
Labelling clause
Implemented by listing in Annex I of the 850/2004
ARTICLE 3 – HBCDD IN ANNEX I
ARTICLE 3 – LISTING OF HBCDD
|
Authorisation under REACH must go hand in hand with
the Stockholm Convention exemption
y
y
|
Limited to use in buildings
2 year authorisation
Prohibition under POP Regulation
y
y
y
Legal issue: Could take place only after REACH autorisation was
known
The EU must register the specific exemption in Annex I due to REACH
authorisation decision
Need to be exempted as long as REACH authorisation will be granted
ARTICLE 7 - WASTE
MANAGEMENT
|
|
|
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1. Producers and holders of waste shall undertake all reasonable efforts to
avoid, where feasible, contamination of this waste with substances listed in
Annex IV.
2. Notwithstanding Directive 96/59/EC ( 2 ), waste consisting of, containing
or contaminated by any substance listed in Annex IV shall be disposed of or
recovered, without undue delay and in accordance with Annex V, part 1 in
such a way as to ensure that the persistent organic pollutant content is
destroyed or irreversibly transformed so that the remaining waste and
releases do not exhibit the characteristics of persistent organic pollutants.
In carrying out such a disposal or recovery, any substance listed in Annex
IV may be isolated from the waste, provided that this substance is
subsequently disposed of in accordance with the first subparagraph.
3. Disposal or recovery operations that may lead to recovery, recycling,
reclamation or re-use of the substances listed in Annex IV shall be
prohibited.
ARTICLE 7 - WASTE
MANAGEMENT
|
|
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4. By way of derogation from paragraph 2: ▼M4
(a) waste containing or contaminated by any substance listed in Annex IV may
be otherwise disposed of or recovered in accordance with the relevant
Community legislation, provided that the content of the listed substances in the
waste is below the concentration limits to be specified in Annex IV. Those
measures, designed to amend non-essential elements of this Regulation, shall be
adopted in accordance with the regulatory procedure with scrutiny referred to in
Article 17(3). Until such time as concentration limits are established in
accordance with such procedure, the competent authority of a Member State may
adopt or apply concentration limits or specific technical requirements in respect
of the disposal or recovery of waste under this point. ▼C1
(b) a Member State or the competent authority designated by that Member State
may, in exceptional cases, allow wastes listed in Annex V, part 2 containing or
contaminated by any substance listed in Annex IV up to concentration limits to
be specified in Annex V, part 2, to be otherwise dealt with in accordance with a
method listed in Annex V, part 2 provided that:
ARTICLE 7 - WASTE
MANAGEMENT
|
|
|
|
(b) a Member State or the competent authority designated by that Member State
may, in exceptional cases, allow wastes listed in Annex V, part 2 containing or
contaminated by any substance listed in Annex IV up to concentration limits to
be specified in Annex V, part 2, to be otherwise dealt with in accordance with a
method listed in Annex V, part 2 provided that:
(i) the holder concerned has demonstrated to the satisfaction of the competent
authority of the Member State concerned that decontamination of the waste in
relation to substances listed in Annex IV was not feasible, and that destruction or
irreversible transformation of the persistent organic pollutant content, performed
in accordance with best environmental practice or best available techniques, does
not represent the environmentally preferable option and the competent authority
has subsequently authorised the alternative operation;
(ii) this operation is in accordance with the relevant Community legislation and
the conditions laid down in relevant additional measures referred to in paragraph
6; and
(iii) the Member State concerned has informed the other Member States and the
Commission of its authorisation and the justification for it.
ARTICLE 7 - WASTE
MANAGEMENT
|
5. Concentration limits in Annex V, part 2 shall be established by the
Commission for the purposes of paragraph 4(b) of this Article. Those
measures, designed to amend non-essential elements of this Regulation,
shall be adopted in accordance with the regulatory procedure with scrutiny
referred to in Article 17(3).
|
Until such time as these concentration limits are established:
(a) the competent authority may adopt or apply concentration limits or specific technical
requirements in respect of waste being dealt with under paragraph 4(b);
(b) where waste is being dealt with under paragraph 4(b), the holders concerned shall
provide information on the persistent organic pollutant content of the waste to the
competent authority.
ARTICLE 7 - WASTE
MANAGEMENT
|
6. The Commission may, where appropriate, and taking into consideration
technical developments and relevant international guidelines and decisions
and any authorisations granted by a Member State, or the competent
authority designated by that Member State in accordance with paragraph 4
and Annex V, adopt additional measures relating to the implementation of
this Article. The Commission shall define a format for the submission of the
information by Member States in accordance with paragraph 4(b)(iii). Such
measures shall be decided in accordance with the procedure laid down in
Article 17(2).
|
7. The Commission shall, before 31 December 2009, review the derogations
in paragraph 4 in the light of international and technical developments, in
particular with regard to their environmental preferability.
ARTICLE 7 - WASTE MANAGEMENT-POPBDE
ARTICLE 7 - WASTE MANAGEMENT HBCDD
30/3/2016
ARTICLE 4 - EXEMPTIONS FROM
CONTROL MEASURES - 1
1. Article 3 shall not apply in the case of:
(a) a substance used for laboratory-scale research or as a reference standard;
(b) a substance occurring as an unintentional trace contaminant in substances, preparations
or articles.
2. Article 3 shall not apply in respect of substances occurring as a constituent
of articles produced before or on the date of entry into force of this Regulation
until six months after the date of its entry into force.
Article 3 shall not apply in the case of a substance occurring as a constituent of
articles already in use before or on the date of entry into force of this
Regulation.
However, immediately upon becoming aware of articles referred to in the first
and second subparagraph, a Member State shall inform the Commission
accordingly.
Whenever the Commission is so informed or otherwise learns of such articles,
it shall, where appropriate, notify the Secretariat of the Convention accordingly
without further delay.
ARTICLE 4 - EXEMPTIONS FROM
CONTROL MEASURES - 2
3. Where a substance is listed in Part A of Annex I or in Part A of Annex II, a
Member State wishing to permit, until the deadline specified in the relevant
Annex, the production and use of that substance as a closed-system site-limited
intermediate shall notify accordingly the Secretariat of the Convention.
|However,
such notification may be made only if the following conditions are
satisfied:
(a) an annotation has been entered in the relevant Annex expressly to the effect that such
production and use of that substance may be permitted;
(b) the manufacturing process will transform the substance into one or more other
substances that do not exhibit the characteristics of a persistent organic pollutant;
(c) it is not expected that either humans or the environment will be exposed to any
significant quantities of the substance during its production and use, as shown through
assessment of that closed system in accordance with Commission Directive 2001/59/EC (
1 ).
ARTICLE 4 - EXEMPTIONS FROM
CONTROL MEASURES - 3
|
The notification shall be communicated also to the other Member States and
to the Commission and shall give details of actual or estimated total
production and use of the substance concerned and the nature of the closedsystem site-limited process, specifying the amount of any non-transformed
and unintentional trace contamination by any persistent organic pollutant
starting material in the final product.
|
The deadlines referred to in the first subparagraph may be amended in cases
where, following a repeat notification from the Member State concerned to
the Secretariat of the Convention, express or tacit consent is issued under
the Convention for the continued production and use of the substance for
another period.
POP REGULATION - 5
WHAT DOES ALL THIS MEAN IN
PRACTICE?
|
Example HBCD
Low POP content value of 1000 mg/kg
y UTC level of 100 mg/kg
y
y
Wastes containing below 1000 mg/kg of that POP do not
have to be treated as POPs wastes and may be recycled.
|
y
For instance, a waste containing 600 mg/kg of HBCD would not be a
POPs waste and could be recycled.
However, the new product made out of the recycled materials
has to meet the UTC level of 100 mg/kg
Æ in this particular case, at least 5 parts of virgin (not
contaminated) material would have to be added to 1 part of waste
material to obtain a new product meeting the UTC level of 10
mg/kg required for products.
THE PROBLEM IS BIGGER IN
DEVELOPED COUNTRIES
31
EXAMPLES OF RELEVANT MATERIALS
0,7 %
HBCD
1-2 % cpentaBDE
3-5 % cpentaBDE
12-18%
oktaBDE
25%
dekaBDE
25%
dekaBDE
3-10 % cpentaBDE
10%
HBCD
12-18%
oktaBDE
12-18%
oktaBDE
25%
dekaBDE
X % cpentaBDE
32
OTHER RELEVANT
LEGISLATION
ENVIRONMENTAL LEGISLATION: AIM-1
REACH ((EC) 1907/2006): Article 1 - Aim and scope
|1.
The purpose of this Regulation is to ensure a high level of protection of human health and
the environment, including the promotion of alternative methods for assessment of hazards of
substances, as well as the free circulation of substances on the internal market while enhancing
competitiveness and innovation.
Waste Framework Directive (2008/98/EC): Article 1- Subject matter and scope
|This
Directive lays down measures to protect the environment and human health by
preventing or reducing the adverse impacts of the generation and management of waste and by
reducing overall impacts of resource use and improving the efficiency of such use.
Waste Electronic Electric Equipment (2012/19/EU): Article 1 - Subject matter
|This
Directive lays down measures to protect the environment and human health by
preventing or reducing the adverse impacts of the generation and management of waste from
electrical and electronic equipment (WEEE) and by reducing overall impacts of resource use
and improving the efficiency of such use in accordance with Articles 1 and 4 of Directive
2008/98/EC, thereby contributing to sustainable development.
ENVIRONMENTAL LEGISLATION: AIM-2
|
POP Regulation ((EC) 850/2004) Article 1 - Objective and scope
|
1. Taking into account, in particular, the precautionary principle, the objective of this
Regulation is to protect human health and the environment from persistent organic
pollutants by prohibiting, phasing out as soon as possible, or restricting the
production, placing on the market and use of substances subject to the Stockholm
Convention on Persistent Organic Pollutants, hereinafter ‘the Convention’, or the
1998 Protocol to the 1979 Convention on Long-Range Transboundary Air Pollution
on Persistent Organic Pollutants, hereinafter ‘the Protocol’, and by minimising, with
a view to eliminating where feasible as soon as possible, releases of such substances,
and by establishing provisions regarding waste consisting of, containing or
contaminated by any of these substances.
DILEMMA
REACH ((EC) 1907/2006): Article 1 - Aim and scope
|1.
The purpose of this Regulation is to ensure a high level of protection of human health and
the environment, including the promotion of alternative methods for assessment of hazards of
substances, as well as the free circulation of substances on the internal market while enhancing
competitiveness and innovation.
Waste Framework Directive (2008/98/EC): Article 1- Subject matter and scope
|This
Directive lays down measures to protect the environment and human health by
preventing or reducing the adverse impacts of the generation and management of waste and by
reducing overall impacts of resource use and improving the efficiency of such use.
Waste Electronic Electric Equipment (2012/19/EU): Article 1 - Subject matter
|This
Directive lays down measures to protect the environment and human health by
preventing or reducing the adverse impacts of the generation and management of waste from
electrical and electronic equipment (WEEE) and by reducing overall impacts of resource use
and improving the efficiency of such use in accordance with Articles 1 and 4 of Directive
2008/98/EC, thereby contributing to sustainable development.
LESSON - 1
European substance and waste legislation have
comparable aims considering human and environmental
protection.
| Often there are other aims as well.
|
FITNESS CHECK EUROPEAN ENV.
LEGISLATION - 1
|
1. Legislation covering hazard identification and classification
|
Classification, labelling and packaging (Regulation No (EC) 1272/2008)
|
Plant protection products (Regulation (EC) No 1107/2009)
|
Biocidal products (Regulation (EU) No 528/2012)
|
REACH, Annex XIII (Regulation (EC) No 1907/2006)
|
Inland transport of dangerous goods (Directive 2008/68/EC)
|
Chemical Agents (Directive 98/24/EC), Asbestos (Directive 2009/148/EC),
Carcinogens and mutagens at work (Directive 2004/37/EC)
FITNESS CHECK EUROPEAN ENV.
LEGISLATION - 2
|
2. Legislation covering risk management measures
|
a. Worker safety and transport legislation
|
Inland transport of dangerous goods (Directive 2008/68/EC)
|
Carcinogens and mutagens at work (Directive 2004/37/EC)
|
Young people at work (Directive 1994/33/EC)
|
Pregnant workers (Directive 1992/85/EEC)
|
Signs at work (Directive 92/58/EEC)
|
Chemical Agents (Directive 98/24/EC)
|
Asbestos (Directive 2009/148/EC)
FITNESS CHECK EUROPEAN ENV.
LEGISLATION - 3
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b. Environmental protection legislation
Industrial emissions (integrated pollution prevention and control) (Directive 2010/75/EU)
Waste framework (Directive 2008/98/EC) and List of Waste
Waste shipments (Regulation (EC) No 1013/2006)
Major-accident hazards involving dangerous substances (Seveso) (Directive 2012/18/EU)
Water Framework (Directive 2000/60/EC)
Urban Waste Water (Directive 91/271/EEC)
Marine Strategy Framework (Directive 2008/56/EC)
Restriction of the use of certain hazardous substances in electrical and electronic equipment
(Directive 2011/65/EU)
End of life vehicles (Directive 2000/53/EC)
Batteries (Directive 2006/66/EC)
Packaging and Packaging Waste (Directive 94/62/EC)
FITNESS CHECK EUROPEAN ENV.
LEGISLATION - 4
|
c. Chemicals control legislation
|
Biocidal products (Regulation (EU) No 528/2012)
|
Plant protection products (Regulation (EC) No 1107/2009)
|
Export and import of hazardous chemicals (Regulation No 649/2012)
|
Persistent organic pollutants (Regulation (EC) 850/2004)
|
|
Contaminants in food and feed (Regulation (EEC) No 315/93 and Directive
2002/32/EC)
Residues of pesticides (Regulation (EC) No 396/2005)
FITNESS CHECK EUROPEAN ENV.
LEGISLATION - 5
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d. Product controls
EU Ecolabel (Regulation (EC) 66/2010)
Safety of toys (Directive 2009/48/EC)
Cosmetic products (Regulation (EC) No 1223/2009)
Detergents (Regulation (EC) No 648/2004)
Drinking Water (Directive 98/83/EC)
Fertilisers (Regulation (EC) No 2003/2003)
Medical devices (Directive 93/42/EEC regarding medical devices, Directive
90/385/EEC regarding active implantable medical devices, and Directive 98/79/EC
regarding in vitro diagnostic medical devices, under revision)15
Aerosol dispensers (Directive 75/324/EEC)
Explosives (Directive 93/15/EEC)
Pressure equipment (Directive 2014/68/EU)
Food contact materials (Regulation (EC) No 10/2011 and Regulation (EC) No
450/2009)
General Product Safety (Directive 2001/95/EC)
FITNESS CHECK EUROPEAN ENV.
LEGISLATION - 6
|
3. Supporting legislation
|
Test methods (Regulation (EC) No 440/2008)
|
Good Laboratory Practice (Directives 2004/9/EC and 2004/10/EC)
|
Protection of animals used for scientific purposes (Directive 2010/63/EU)
Waste legislation
•WFD
•ELV
•WEEE
REACH, manufacture,
placing on the market
and use of substances,
mixtures and articles
POPs, persistent
organic pollutants
CLP, classification
Hazardous waste
Transport of waste
EVOA)
waste
Product-legislation
•Toys
•RoHS
•FCM
substances and products
LESSON - 2
There is an amount of environmental EU legislation,
some of which are of direct importance for our work
| Although the focus is on waste, attention should also be
paid to new applications
| Except for comparable aims, there may be comparable
limits. Not per definition similar limits!
| Most of these limits relate back to CLP regulation
|
DIRECTIVE 2012/19/EU (WEEE)
WEEE = Waste Electrical and Electronic Equipment
| Article 8 – Proper treatment
|
y
2. Proper treatment, other than preparing for re-use, and
recovery or recycling operations shall, as a minimum, include
the removal of all fluids and a selective treatment in
accordance with Annex VII.
DIRECTIVE 2012/19/EU (WEEE)
|
Article 19 Adaption to scientific and technical progress
y
…. When amending Annex VII, the exemptions granted
under Directive 2011/65/EU of the European Parliament and
of the Council of 8 June 2011 on the restriction of the use of
certain hazardous substances in electrical and electronic
equipment ( 3 ) shall be taken into consideration.
DIRECTIVE 2012/19/EU (WEEE)
|
Annex VII - Selective treatment for materials and
components of waste electrical and electronic equipment
referred to in Article 8(2)
y
1. As a minimum the following substances, mixtures and
components have to be removed from any separately
collected WEEE:
— batteries,
| — toner cartridges, liquid and paste, as well as colour toner,
| — plastic containing brominated flame retardants,
| — cathode ray tubes,
|
DIRECTIVE 2011/65/EU (ROHS)
RoHS = Restriction of Hazardous Substances
| Chapeau (10) – update of measures: HBCDD
|
y
The measures provided for in this Directive should take into
account existing international guidelines and
recommendations and should be based on an assessment of
available scientific and technical information. The annexes to
this Directive should be reviewed periodically to take into
account, inter alia, Annexes XIV and XVII to Regulation
(EC) (REACH). Hexabromocyclododecane (HBCDD), Bis
(2-ethylhexyl) phthalate (DEHP), Butyl benzyl phthalate
(BBP) and Dibutyl phthalate (DBP) should be considered as a
priority.
DIRECTIVE 2011/65/EU (ROHS)
|
Article 4.1 - Member States shall ensure that EEE placed
on the market, including cables and spare parts for its
repair, its reuse, updating of its functionalities or
upgrading of its capacity, does not contain the substances
listed in Annex II.
DIRECTIVE 2000/53/EC (ELV)
ELV = End-of Life Vehicles
| Chapeau (11 + 24) – design + autorized dismantling
|
(11) It is important that preventive measures be applied from
the conception phase of the vehicle onwards and take the
form, in particular, of reduction and control of hazardous
substances in vehicles,… This will help to ensure that certain
materials and components do not become shredder residues,
and are not incinerated or disposed of in landfills.
y (24) In order to facilitate the dismantling and recovery, in
particular recycling of end-of life vehicles, vehicle
manufacturers should provide authorised treatment
facilities with all requisite dismantling information, in
particular for hazardous materials.
y
DIRECTIVE 2000/53/EC (ELV)
|
Article 2.11 definition hazardous substances
y
‘hazardous substance’ means any substance which fulfils the
criteria for any of the following hazard classes or categories
set out in Annex I of Regulation (EC) No 1272/2008 of the
European Parliament and of the Council of 16 December
2008 on classification, labelling and packaging of substances
and mixtures ( );
1
DIRECTIVE 2000/53/EC (ELV)
|
Article 4 – Prevention
y
1(a) vehicle manufacturers, in liaison with material and
equipment manufacturers, to limit the use of hazardous
substances in vehicles and to reduce them as far as possible
from the conception of the vehicle onwards, so as in
particular to prevent their release into the environment, make
recycling easier, and avoid the need to dispose of hazardous
waste;
DIRECTIVE 2000/53/EC (ELV)
|
Article 6 – Treatment
y
3 (b) hazardous materials and components shall be removed
and segregated in a selective way so as not to contaminate
subsequent shredder waste from end-of life vehicles;
LESSONS 3
General starting point – protection of people and
environment
| Links with other legislation: i.e. CLP, REACH
| Often combination of substances + concentrations
| Concentrations = POP Regulation:
|
article 4.1 = Unintentional Trace Contaminant = marketing
and use
y annex I = marketing and use
y Annex IV = low POP limit waste
y
LESSONS 4
|
Always a combination of new products and waste
Design and prevention of hazardous substances/POPs
y Recycling (below low POP limit = annex IV or specific limit)
y
Authorized treatment facilities and information along the
chain (ELV, RoHS, WEEE)
| Update with new information (not always yet
implemented)
|