Aluminium Recycling Process PDF
Aluminium Recycling Process PDF
Aluminium Recycling Process PDF
Technical Proposals
European Commission
Joint Research Centre
Institute for Prospective Technological Studies
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JRC 58527
EUR 24396 EN
ISBN 978-92-79-15990-9
ISSN 1018-5593
doi:10.2791/43228
Printed in Spain
Preface
PREFACE
This report is the JRC-IPTS contribution to the development of the end-of-waste criteria for
aluminium scrap in accordance with Article 6 of Directive 2008/98/EC of the European
Parliament and of the Council on waste (the Waste Framework Directive).
The purpose of end-of-waste criteria is to avoid confusion about the waste definition and to
clarify when certain waste that has undergone recovery ceases to be waste. Recycling should be
supported by creating legal certainty and an equal level playing field and by removing
unnecessary administrative burdens. The end-of-waste criteria should provide a high level of
environmental protection and an environmental and economic benefit.
The recitals of the Waste Framework Directive identify scrap metals as a possible category of
waste for which end-of-waste criteria should be developed. Consequently, the Environment
Directorate-General requested from the JRC-IPTS a study with technical proposals on end-of-
waste criteria for aluminium and aluminium alloy scrap.
This report delivers the results of the study. It includes a possible set of end-of-waste criteria
and shows how the proposals were developed based on a comprehensive techno-economic
analysis of aluminium and aluminium alloy recycling and an analysis of the economic,
environmental and legal impacts when aluminium scrap cease to be wastes.
The report has been produced by the JRC-IPTS based on the contributions of experts from
Member States and the stakeholders by means of a TWG. The experts contributed in the form of
written inputs and through participation in a workshop organised by the JRC-IPTS in July 2009.
The report also used the results of previous research carried out by the JRC-IPTS from 2006 to
2008 and described in the reports 'End-of-waste criteria' and 'Study on the selection of waste
streams for end-of-waste assessment'.
1
TABLE OF CONTENTS
PREFACE ...................................................................................................................................................1
GLOSSARY ................................................................................................................................................3
INTRODUCTION ......................................................................................................................................5
1 ANALYSIS..........................................................................................................................................7
1.1 Scrap sources ..............................................................................................................................7
1.2 Secondary aluminium production.............................................................................................11
1.3 Recycling processes..................................................................................................................11
1.4 Industry structure......................................................................................................................14
1.5 Economy and market ................................................................................................................15
1.6 Specifications and standards.....................................................................................................18
1.7 Legislation and regulation ........................................................................................................19
1.8 Environmental and health aspects.............................................................................................20
2 END-OF-WASTE CRITERIA........................................................................................................23
2.1 Rationale for end-of-waste criteria ...........................................................................................23
2.2 Conditions for end-of-waste criteria .........................................................................................23
2.3 Outline of end-of-waste criteria................................................................................................24
2.4 Criteria on product quality........................................................................................................25
2.5 Criteria on input materials ........................................................................................................33
2.6 Criteria on treatment processes and techniques ........................................................................34
2.7 Quality assurance......................................................................................................................36
2.8 Application of end-of-waste criteria .........................................................................................38
3 IMPACTS .........................................................................................................................................39
3.1 Environmental and health impacts............................................................................................39
3.2 Economic impacts.....................................................................................................................40
3.3 Legal impacts............................................................................................................................42
4 CONCLUSIONS ..............................................................................................................................51
5 REFERENCES.................................................................................................................................53
ANNEXES .................................................................................................................................................55
Annex 1. Summarised standards en 13920 on aluminium and aluminium alloy scrap...........................56
Annex 2. Aluminium scrap categories according to Institute of Scrap Recycling Industries (ISRI)......58
Annex 3. Summarised criteria ................................................................................................................59
2
Glossary
GLOSSARY
APEAL Association of European Producers of Steel for Packaging
ASR Automotive shredder residue
BIR Bureau of International Recycling
CFCs Chlorofluorocarbons
ECHA European Chemical Agency
EEE Electrical and electronic equipment
EFR European Ferrous Recovery & Recycling Federation
ELVs End-of-life vehicles
EoW End-of-waste
EU European Union
EUROFER European Confederation of Iron and Steel Industries
FER Federacin Espaola de la Recuperacin y el Reciclaje
GHG Greenhouse gas
JRC-IPTS Joint Research Centre- Institute for Prospective Technological Studies
LME London Metal Exchange
PBT Persistent, Bioaccumulative and Toxic chemicals
PVC Polyvinyl chloride
REACH Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
SDS Safety Data Sheet
TWG Technical Working Group
UBCs Used beverage cans
UNECE United Nations Economic Commission for Europe
vPvB very Persistent, very Bioaccumulative
VAT Value added tax
WEEE Waste electrical and electronic equipment
WFD Waste Framework Directive
3
4
Introduction
INTRODUCTION
Background
According to Article 6 (1) and (2) of the new Waste Framework Directive (WFD) 2008/98/EC,
certain specified waste shall cease to be waste when it has undergone a recovery operation and
complies with specific criteria to be developed in line with certain legal conditions, in particular
when there is an existing market or demand for the material and the use is lawful and will not
lead to overall negative environmental or human health impacts. Such criteria should be set for
specific materials by the Commission in comitology. The end-of-waste criteria mechanism was
introduced to further encourage recycling in the EU by creating legal certainty and an equal
level playing field and removing unnecessary administrative burden.
A methodology guideline to develop end-of-waste criteria has been elaborated by the Joint
Research Centre the Institute for Prospective Technological Studies (JRC-IPTS) and is
documented in Chapter 1 of the JRC "End-of-Waste Criteria" report. The European
Commission preparing proposals for end-of-waste criteria for specific waste streams according
to the legal conditions and following the JRC methodology guidelines. As part of this work, the
JRC-IPTS has conducted a study with the aim to prepare technical proposals for aluminium
scrap.
Process
The technical proposals were developed based on the contributions of experts from Member
States and the stakeholders by means of a TWG. The experts were requested to make their
contribution in the form of written inputs and through participation in the expert workshop
organised by the JRC-IPTS on 2 July 2009. Before the workshop, the JRC-IPTS submitted a
background paper to the TWG in order to prepare for the work, to collect the necessary
information from the experts and to have previously collected information peer-reviewed within
the TWG. Shortly after the workshop, the JRC-IPTS wrote to the TWG with the request for
additional inputs. A first draft of the final report was made available to the TWG for comments
in September 2009. The final report was prepared by the JRC-IPTS based on the inputs and
comments from the TWG throughout the whole process.
The second part deals with the end-of-waste criteria as such. It identifies the reasons for
developing the end-of-waste criteria for aluminium scrap, i.e. the advantages they offer
compared to the current situation. It then analyses how the basic general conditions for the end-
of-waste criteria can be fulfilled and finally it proposes outlines of possible end-of-waste criteria
including a quality assurance system.
The third part addresses potential environmental, economic and legal impacts of implementing
the end-of-waste criteria.
5
Analysis
1 ANALYSIS
The development of end-of-waste criteria requires consideration of the characteristics of waste
streams, the structure of the industry, the economics, the market situation and trade flows, the
existing regulations and standards/specifications, and the environmental and health aspects. The
following sections look at these issues throughout the entire recycling chain of aluminium scrap.
New scrap is generated during the initial manufacturing processes. All secondary aluminium
residues are treated by refiners or remelters. The composition of new scrap is well known and in
principle new scrap does not need any pretreatment process before it is remelted, although
cutting to size might be necessary. New scrap could be considered a by-product and not waste
(Paragraph 1.7). New scrap with paint or coating, excluding cable and composite material of
aluminium and plastic may require special processing.
Old scrap is collected after a consumer cycle, either separately or mixed, and it is often
contaminated to a certain degree, depending highly on its origin and collection systems. Since
the lifetime of many metal products can be more than ten years and sometimes more than 50
years, for instance products for building and construction, there has been an accumulation of
metal in use since the start of the industry.
According to industry, currently around 540 Mt of aluminium products are in use and nearly 8
Mt of old aluminium scrap were generated worldwide in the year 2004. Scrap generation has
doubled since 1990 and is expected to increase further mainly due to the continuous increase of
aluminium content in products such as vehicles over the last 15 years and the improved
collection of packaging materials such as beverage cans. In the EU (data for EU-25), the total
recycled old scrap was 2 Mt in 2004 and the total aluminium in use amounted to nearly 120 Mt.
The key sources of aluminium scrap are shown in Figure 1.
Construction
Cable, wire, Transportation
and building
EEE and facility and
7%
others vehicles
21% 44%
Packaging
28%
Another way to classify scrap sources is according to the products in which the metal was used
before it became a waste. The main aluminium scrap sources in this sense are vehicles, metal
products for construction, cables and wires, electrical and electronic equipment and packaging.
7
Analysis
Packaging
Aluminium packaging waste is a large short term source of scrap. Most of the products used in
food packaging have a lifetime of less than one year. The current consumption is close to 5 Mt
per year. The sector contributes nearly 28 % of recycled aluminium, second after the
transportation sector. For used beverage cans alone, the collection rates are as high as 80 to
93 % in some European countries (the Benelux, Scandinavian countries and Switzerland). The
mean collection rate of aluminium beverage cans in Western Europe, which has been monitored
since 1991, has almost tripled from 21 % in 1991 to 57.7 % in 2006.
It is estimated that each EU citizen currently produces around 17 20 kg per year of waste from
electrical and electronic equipment (WEEE) which adds up to 9 million 10 million tonnes at
the Community level. Expected growth rates are between 3 and 5 % each year. This means that
in five years time, 16 28 % more WEEE will be generated and in 12 years the amount is
expected to double. This rapid growth rate is due to the fast pace of technological development,
especially in information technology which has resulted in the more frequent replacement of
electrical and electronic equipment by industry.
8
Analysis
The main use of aluminium in this sector is to provide materials for roofing and cladding, and
window and door frames, as well as small size applications such as shutters, door handles,
ceiling partitions, etc. The collection rate of aluminium scrap from building deconstruction and
demolition in six European countries has been shown to be between 92 and 98 % even though
the aluminium content in building (by mass) is below 1 %. While the collection of the small
sized items depends largely on the demolition method, the large sized items are often collected
separately to be sold directly for reuse or sent to a recycling plant.
Another way to classify scrap sources is according to waste categories. Waste which contains
aluminium scrap is likely to be classified in one of the categories according to the European
Waste List that are included in Table 1.
9
Analysis
Table 1: Examples of waste categories according to the European Waste List that may
contain aluminium scrap.
10
Analysis
Old and new scraps are processed prior to melting by methods that depend on any
contamination that may be present. Aluminium turnings are usually contaminated with oil,
water and iron. They are therefore washed and dried to remove oil and water and then
magnetically processed to remove iron. Aluminium beverage cans are processed to remove the
lacquer coating that would otherwise lead to an increase in fume emission during melting.
Several melting processes are used depending on the scrap quality.
Clean, uncoated scrap can be melted in a reverberatory furnace; finely divided scrap, such as
turnings, are ideally melted in a coreless induction furnace; contaminated lower grades of scrap
are melted under a flux cover in a rotary furnace and aluminium components contaminated with
other metals such as steel bolts can be melted in a sloping hearth furnace.
The wrought remelts take good quality old and new scrap and convert this into extrusion billet
or rolling slab, usually of the same alloy. Good examples are the conversion of old and new
extrusion scrap into billet for extrusion production, and used aluminium beverage cans into
rolling slab for the production of more aluminium beverage cans.
Scrap metal is collected either separately or mixed and then sorted in the scrap yard and
then sold to scrap treatment plants or sent directly to a refiner/remelter.
Arriving at the scrap treatment plant, different types of metals are further separated and
prepared for shredding/sizing. Shredding and sizing is often needed for a further stage of
separation. First, while shredding and cutting, magnetic separation is used to single out
the ferrous metal. Then, using several media separation technologies, the non-ferrous
metal is separated first from non-metal elements and then different non-ferrous metals are
separated.
If shredded scrap metal is wet or dirty, it needs to be dried or to be further cleaned of
possible contaminants such as oil, grease, lubricants, lacquers, rubber, and plastic
laminates.
At the aluminium refinery, scrap metal is first cleaned, if necessary, from contaminants at below
melting temperature in kilns and then charged to the furnace going through melting,
fluxing/refining, and tapping.
Although not all the origins of scrap are included here, it is believed that their treatment process
resembles those that are described in Figure 2.
11
Analysis
End-of-life vehicles:
Today in the EU when a passenger car (as main
example for end-of-life vehicles) reaches its end of
life, it is brought to a specific collection point, which
in some cases could also be a generic scrap treatment
plant. ELVs are treated (depolluted) according to a
certain procedure guided by the ELV Directive, as
shown in the diagram. ELVs are first decontaminated
by removing various fluids and parts. The rest of the
car, including the body, the interior, etc. is fed into a
shredder. In the shredding process, magnetic
separation is used to remove the magnetic ferrous
fraction, leaving non-ferrous metals and non-metallic
materials to pass to further stages, i.e. dense media
separation and eddy-current separator, for the
Shredder segregation of one type from another. The separated
Shredder
Media
Media
ferrous part contains as much as 98 % metal. More
than 99 % of the non-ferrous metal can be recovered.
Further advanced technology for the separation of
alloys is being developed for industrial applications.
To a certain extent, other recyclable fractions such as
glass and plastics are also recovered at this stage.
The dust and the separated residues together usually represent about 17 to 25 % of the weight of
an average vehicle. In the past, they have been landfilled, representing no more than 0.2 % of
total landfill waste in the EU. However, with the implementation of the ELV Directive, which
requires 85 % (increasing to 95 % in 2015) of an ELV to be re-used, recycled, or recovered,
these residues are progressively being reduced.
Whilst sink-float separation is shown here in the diagram, where typically a ferrosilicon
suspension is used to achieve the separation of materials of differing densities, followed by a
washing stage, new alternative dry technologies are being developed using a variety of sensors
and separation techniques.
12
Analysis
On arrival at the refinery, the baled aluminium can is first shredded into small-sized pieces, and
is then passed through a magnetic field to remove any remaining steel contaminants. Next, the
shreds need to be cleaned of paint, ink, coating, etc. by blowing in hot air at a temperature of
500 C. After the decoater, the shreds are fed into melting furnaces. At this stage, salt is usually
added to remove the impurities and to improve the quality of the product. The molten
aluminium is then cast into ingots.
According to BIR, the predominant way of recovering the metal from cable scrap in developed
countries is by automated cable chopping. Most cable chopping plants process only copper
cable scrap, a few plants process aluminium cable scrap, and some operate both a line for
aluminium and another for copper cable scrap.
Pre-sorting: to separate cable scrap by type of insulation, by conductor diameter, etc. and
to prepare it for feeding into the shredder. Pre-sorting also includes sorting copper from
aluminium-containing cable and removing unsuitable cables before entering the
automatic chopping system. As shown in the picture, pre-sorting can already result in
fairly clean scrap. The pre-sorting allows the maximum value for the recovered metal
scrap to be obtained and makes further separation of plastics easier.
Cable chopping: usually desirable for processing long cable sections. It is the first step in
reducing the size of the cable. Compared to shredding, cable chopping produces little, if
any, filter dust.
Granulation: carried out twice so that the cable chops are of a sufficiently fine size to
ensure that most of the insulation is liberated from the cable. Inevitably however, small
amounts of metal remain embedded in the plastic.
Screening: to enhance the recovery of metal, some chopping lines also use vibrating
screen to yield the desired chop size. The smaller the chop size is, the more efficient the
removal of the metal.
Density separation: similar-sized chop fractions that collect on the screens are discharged
and fed to an air table being fluidised and separated into two fractions: clean metal
products and essentially metal-free tailings. Generally, middling fractions are
reprocessed again in the system or can be re-tabled.
The metal content of residue streams can vary from less than 1 % to more than 15 %. If a dry
electrostatic system is used, the metal content may be reduced to less than 0.1 %, which will
consequently increase the value of the recovered plastic.
An example is the cable scrap, which is usually a mixture of copper or aluminium conductors
with rubber, plastic or paper insulation. They may also have steel or lead armouring. Pre-sorting
in such a case is very difficult.
13
Analysis
done at different stages of the treatment process depending on the implementation of the
Directive in Member States.
After de-pollution, WEEE consists chiefly of a mixture of metal, plastics and glass. From here,
the treatment of WEEE in general has the following steps, though the process may vary with
different combinations of: shredding, granulating (more than once), magnetic separation, and
eddy current separation (more than once), there is also the possibility of density separation on
the separation table and/or hand separation (Figure 3).
The stainless steel, aluminium and copper fractions are separated from other ferrous metal and
other non-ferrous metal during these processes and can be sent directly to the steelworks or
refineries. The metal content in the plastic could be high; however it is possible to further
recover these metals later during the plastic recycling process or, if the plastic is incinerated,
from the bottom ash of the incinerators.
14
Analysis
Refining
Remelting
Depending on the type of product and the country, the collection system can vary. Large-sized
and quantity end-of-life products, such as those from construction and demolition, are usually
transported directly to the scrap yard or scrap treatment plants. Both ELVs and WEEE place the
responsibility of recycling, hence scrap collection, on the producers. Small products such as
packaging materials are collected by the local authorities, which means that in this case,
collection is not in the hands of the scrap metal industry, though some industry initiatives are
taken in the case of UBCs, e.g. collection centre, scrap terminals, where aluminium cans are
separated and baled for transportation to treatment plants or refineries.
EUROSTAT 2006 waste statistics recognise 50 682 recycling installations in the EU-27, of
these the metal recycling federations estimate some 40000 will deal with aluminium. There are
307 shredders in the EU-27 and downstream media separation plants and most of them will
have an output of shredded aluminium scrap. The secondary aluminium processors, i.e. refiners
and remelters, are mostly small and medium in size and, according to EAA/OEA, there are 123
refining plants and the same number of remelting plants in Europe in 2009.
The production of recycled aluminium and aluminium casting from 2003 until 2007 is shown in
Table 2.
15
Analysis
Table 2: Production of recycled aluminium and aluminium casting from 2003 to 2007 in
Europe (in 1000 tonnes).
Table 3 shows that in 2007 in the EU-15 there were 133 refiners producing casting alloys and
deoxidation aluminium and 107 remelters producing wrought alloys in the shape of extrusion
billets and rolling slabs, with the number of employees amounting to approximately 10000.
Scrap trade within the EU as well as import and export to other countries has been established
for decades. The amount of aluminium scrap (new and old) shipped within Europe was
estimated being 5 Mt in 2004. According to EUROSTAT (intrastat and extrastat), the import
and export in 2008 is shown in Table 4.
16
Analysis
Table 4: Intrastat and extrastat aluminium scrap figures in tonnes for each of the EU-27
member states in 2008.
EU-27_EXTRA EU-27_INTRA
COUNTRY
IMPORT EXPORT IMPORT EXPORT
AUSTRIA 23722 1929 73244
BELGIUM 9091 41501 143101 111328
BULGARIA 52 0 544
CYPRUS 1518 1 2892
CZECH
931 190 57493 59007
REPUBLIC
DENMARK 1424 20287 69302 36440
ESTONIA 124 2398 361 17496
FINLAND 25 8371 21953 28974
FRANCE 11677 17491 183344 324705
GERMANY 79186 78448 464652 624291
GREECE 22573 4763 6388 8499
HUNGARY 4920 37 51426 22060
IRELAND 132 3543 2 17497
ITALY 74108 9744 303337 46469
LATVIA 213 1165 7464 3038
LITHUANIA 647 1835 1286 3510
LUXEMBOURG 19473 1885 103933 9278
MALTA 530 1 912
NETHERLANDS 35038 68217 166220 194067
POLAND 20 296 67156 123172
PORTUGAL 89 388 2321 39587
ROMANIA 336 1863 262 14157
SLOVAKIA 0 4638 10109
SLOVENIA 4491 3077 19403 8813
SPAIN 13587 4489 87810 104783
SWEDEN 19898 18738 20228 87843
UNITED
37341 759792 110531 113235
KINGDOM
TOTAL 359098 1052495 1892613 2085950
In last few years, before the financial crisis, the demand for scrap rose worldwide. The
collection rate of non-ferrous metals increased in all sectors in the EU. In the second half of
2008, with the onset of the global financial and economic crisis, falling output among many
metal processing companies has resulted in low levels of demand for scrap; many consumers
have announced plant closures, production curtailments or reductions of employee working
hours. The price of aluminium scrap decreased by half compared to spring 2008 (see Figure 5).
However at the end of 2009 prices were still comparable to aluminium scrap prices in 2005.
Prices recuperated somewhat in early 2009.
17
Analysis
2000
1500
1000
500
November
November
November
November
June
June
June
June
June
January
July
January
July
January
July
January
July
January
July
March
March
March
March
March
September
October
September
October
September
Oktober
September
Oktober
September
Oktober
December
December
Dezember
Dezember
Dezember
May
May
May
May
May
February
February
February
February
February
April
April
April
April
April
August
August
August
August
August
2004 2005 2006 2007 2008
Traded scrap metal is basically classified according to several properties, most notably:
ISRI specifications
Developed by the USA Trade Association, the Institute of Scrap Recycling Industries (ISRI),
this American specification classifies the following: non-ferrous Scrap, ferrous scrap, glass
cullet, paper stock, plastic scrap, electronics scrap, tyre scrap; and is used internationally. The
ISRI specification for aluminium scrap is shown in Annex 2.
Bilateral contract/specification
As already mentioned, there are also specifications made as agreements or contracts in trade
between two parties. Such specifications are usually based on a standard classification with
additional requirements suitable for the desired production process or product. In this case, the
specifications are being continuously reviewed and, if necessary, modified.
18
Analysis
Scrap treatment plants (e.g. shredders, dismantlers, media separation plants) as well as scrap
collectors and sorting plants are operated under a permit for waste treatment, although the
details of their permits vary across member states.
The production of secondary aluminium and the associated treatment of scrap metal on site are
subject to the IPPC Directive. The current discussion on the possible extension of the scope of
Directive 2008/1/EC of the European Parliament and of the Council of 15 January 2008
concerning integrated pollution prevention and control (the IPPC Directive) in relation to waste
treatment activities has suggested the inclusion of separate installations for scrap metal
treatment.
Certain metal-containing waste streams are regulated under specific directives, such as the
WEEE, the ELV Directive and the Directive on packaging and packaging waste. In these
directives, the following elements regarding the treatment and processing of the types of waste
are described and they ensure the proper handling of the waste stream:
The WEEE Directive includes compliance with minimum standards for recycling and
treatment;
The ELV Directive includes minimum technical requirements for the treatment.
Waste shipment
On 12 July 2007, Regulation (EC) No 1013/2006 (the new Waste Shipment Regulation) came
into force. Accordingly, most metal scrap is under the List B of Part 1 of Annex V (also referred
to as the green list), which are not covered by Article 1(1) (a) of the Basel Convention, and
therefore are not covered by the export prohibition.
Export of waste under the green list within the OECD countries is not subject to notification
and consent procedure and is done under normal commercial transactions; however, the new
Waste Regulation does require the completion of an Annex VII form.
For green list exports to non-OECD countries, the regulations require the Commission to
obtain a new declaration from the receiving country as to whether it will accept each kind of
waste; it may also require pre-notification.
In List B, the possibly affected wastes are some metal scrap under B1010 (ferrous and
aluminium) GC010 (electronic assemblies consisting of only metals or alloys) and GC020
(electronic scrap, e.g. printed circuit boards, electronic components, wire) and reclaimed
electronic components suitable for base and precious metal recovery). However, some of the
non-OECD countries failed to respond and where no reply is received, those countries are to be
regarded as having chosen a procedure of prior written notification and consent. Default
controls of prior written notification and consent are applied.
When scrap is traded under the procedure of prior notification and consent, exporters of scrap
metals to non-OECD countries are required to pre-notify, which requires administration and
payment of a fee as well as the establishment of a financial guarantee(1).
In any case, the Waste Shipment Regulation allows exports from the Community only if the
facility that receives the waste (i.e. the secondary metal/steel production plant) is operated in
accordance with human health and environmental standards that are broadly equivalent to
standards established in Community legislation (IPPC).
(1) A financial guarantee is not required in cases of shipment of green listed waste to EU Member States with
transitional provisions to control such waste under the Amber control procedure.
19
Analysis
Shipments of waste (e.g. waste metals) exceeding the limit values of radioactivity defined by
the EC Directive 2006/117/Euratom, which refers to the concentration limits in Directive
96/29/Euratom, require the appropriate regulatory approvals in accordance with the radiation
protection legislation and fall outside the scope of the Waste Shipment Regulation. However,
scrap showing radioactivity below the thresholds of the radiation protection legislation fall
within the scope of the Waste Shipment Regulation No. 1013/2006. Most Member States
classify low radioactive waste as unlisted waste requiring notification, arguing that there is an
increased risk associated with the waste.
The end-of-waste will affect metal scrap that has fulfilled the criteria and become
product/secondary material in such a way that the trading will be not under the waste shipment
regime. The impact on waste shipment is described in Chapter 3.
By-products
If a certain metal scrap generated, for example by the metal processing industry, were regarded
as being a by-product, and not being waste, as defined by Article 5 of the WFD, then 'end-of-
waste criteria' would not apply unless the by-product were later to become waste.
1. A substance or object, resulting from a production process, the primary aim of which is
not the production of that item, may be regarded as not being waste referred to in point
(1) of Article 3 but as being a by product only if the following conditions are met:
2. On the basis of the conditions laid down in paragraph 1, measures may be adopted to
determine the criteria to be met for specific substances or objects to be regarded as a by-
product and not as waste referred to in point (1) of Article 3. Those measures, designed to
amend non-essential elements of this Directive by supplementing it, shall be adopted in
accordance with the regulatory procedure with scrutiny referred to in Article 39(2).
What is noteworthy is that Article 5 of the WFD says may be regarded, which appears to
leave a certain freedom of choice even if the four conditions of Article 5 are met, at least as long
as measures under Article 5.2 have not been adopted.
REACH
When metal scrap ceases to be waste, it becomes subject to the provisions of the REACH
Regulation. The implications of this are discussed in detail in Chapter 3.
20
Analysis
The mechanical handling of scrap and scrap processing removes some coatings as an effect of
the processing. In the case of shredding scrap metal, the processing in the hammer mill removes
most of the paint/coatings from the metal except for zinc coatings which remain mainly on scrap
fragments after shredding. The removed paint/coatings are separated from the scrap metal and
are collected into the shredder residue.
Some processes have a specific decoating step. Residual paint/coatings are removed in the metal
works as part of the process, either contributing to slag generation or air emissions. PVC and
other halogenated coatings may contribute to the generation of dioxins and furans. However, a
link on the composition of the input materials and the emissions of these substances has not
been demonstrated. The emissions are determined by the process and by treatment of the flue-
gas.
Radioactive scrap metal can occur in a number of different ways. Some of the main origins are
the demolition or decommissioning of industrial facilities processing raw materials containing
naturally-occurring radionuclides, the decommissioning of nuclear installations (such as nuclear
power plants and other nuclear fuel cycle facilities) and other facilities, loss of sources (sealed
radioactive sources are sometimes lost or mislaid and they may be collected as scrap metal),
demolition of facilities in which radioactive sources have been used, incorporation of old
radioactive devices into scrap (items such as timepieces and compasses covered with
radioluminous paint, lightning rods, thoriated lenses, etc. may be collected as scrap).
In order to minimise the risks, radioactivity needs to be measured systematically. The United
Nations Economic Commission for Europe (UNECE) has released recommendations to monitor
and reduce the risks involving radioactivity in scrap metal. While these recommendations are
not legally binding, they provide guidance based on existing best practice to all interested
parties (scrap yards, metal smelters, customs, regulatory authorities and transporters, amongst
others).
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End-of-waste criteria
2 END-OF-WASTE CRITERIA
The main types of benefits that can be expected when EU-wide end-of-waste criteria for
aluminium scrap are introduced are given below:
Improved functioning of the internal market (simplified and harmonised rules across
countries).
Clearer differentiation between high quality scrap and low-quality scrap. Only high
quality scrap will cease to be waste.
Reduction of administrative burdens especially related to shipment and transport.
Regarding the first two conditions, it is evident in the case of aluminium scrap that a structured
market exists (e.g. there are classifications of scrap metal used for trading). Aluminium scrap is
commonly used as a feedstock in re-melting and refining to produce new aluminium (secondary
aluminium). There is generally a demand by the aluminium industry for scrap that complies
with specification or standard such as the 'EN 13920' and any other use than for the production
of new aluminium is highly unlikely. This is also true in the case of exports from the EU,
including to non-OECD countries.
The third condition implies that end-of-waste criteria need to ensure that, at the point of ceasing
to be waste, any technical requirement related to use are fulfilled and the recycled material
comply with applicable legislation and standards as product. In the case of aluminium scrap,
this means that at the moment of end-of-waste, the scrap should fulfil standards/specifications
that the secondary aluminium industry uses for the scrap it buys.
From a life cycle point of view, aluminium scrap metal recycling as such has overall
environmental benefits (especially the energy related air emissions). The use of scrap metal in
the furnace is regulated as far as emissions are concerned by the IPPC Directive regardless of
whether the scrap is a waste or not. Also, outside the EU, process emission control of secondary
metal production does not depend on the waste status of the scrap.
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End-of-waste criteria
The main areas where the waste status of aluminium scrap can potentially make a difference for
the environmental and health impacts is transport and trade (waste shipment). If scrap has end-
of-waste status, it can in principle be transported by any transport undertaking and not only
those that are permitted to transport waste. It is important that only scrap without waste-specific
hazardous properties cease to be waste.
Regarding waste shipment, it is important that only scrap for which it is highly likely that it will
actually be used for secondary metal production be exported and imported outside waste
regulatory controls (waste shipment regulation). It is therefore also important regarding the
fourth condition that the scrap be processed to comply with the standards and specifications of
the scrap-using industry so that a demand by the metal industry effectively exists.
The TWG confirmed the appropriateness of this approach for the case of aluminium scrap and
that the approach of combining different types of requirements in a set of end-of-waste criteria
corresponds well to the good industrial practice of ensuring the product quality of the scrap. The
TWG also supported the view that the existing recycling system should not be disturbed by end-
of-waste criteria for aluminium scrap. There should be a clear identification where scrap has
attained a quality that is sufficient to ensure that no environmental risks occur when scrap is
transported, further processed or traded without being controlled as waste.
During the workshop in July 2009 and by other input, many experts stressed the need to keep
the criteria clear, as simple as possible, and enforceable. It was suggested to reinforce the role of
the direct product quality requirements, in particular to provide criteria that are useful in the
case of spot checks of traded material and which would allow demonstrating non-compliance
with the end-of-waste criteria directly. As already proposed in earlier papers, the direct product
requirements should address certain direct hazards for the environment and human health such
as related to radioactivity and oil content. In addition, strong support was widely given to the
concept of a general quantitative criterion, such as a limit on metal content, content of foreign
materials or metal yield, that would serve as a check for the completeness of treatment and as a
check that the metal is sufficiently pure for safe use. All types of aluminium scrap would have
to meet this limit value in order to benefit from end-of-waste status.
Quality assurance was another element of the end-of-waste criteria that the technical working
group considered as especially important and useful because it is needed to establish sufficient
confidence in the end-of-waste status.
At the same time, the discussions of the TWG showed that the requirements on input materials
and treatment processes should mainly address and be stringent regarding those materials that
pose a specific hazard if not treated adequately. Since the use and treatment of waste which
contains non-hazardous metals to produce aluminium scrap was less of a concern; many experts
suggested that the end-of-waste criteria could be less specific regarding these aspects.
The different possible elements of the end-of-waste criteria, the main considerations made by
the TWG and the resulting proposals are discussed in the subsequent sections and are
summarised in Annex 3.
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End-of-waste criteria
A limit value on metal yield, metal content or non-metallic components can be used in
compliance testing by the producer of end-of-waste scrap (at the site of the processor) as well as
in on-the-spot checks, for example by regulatory authorities.
For the sake of clarity, the same limit value should apply to all types/categories of aluminium
scrap. (Stricter requirements in specifications, standards and commercial agreements for specific
types of scrap will of course be possible.)
Bellow all three types of limit values are discussed, although not all of the options should
ultimately be included in the end-of-waste criteria.
The definition of foreign materials could be similar to that of steriles (as defined in the case of
iron and steel scrap). Steriles are defined in the European Steel Scrap Specification as non-
ferrous metals, non-metallic materials, combustible non-metallic materials, larger pieces (brick-
size) which are non-conductors of electricity such as tyres, pipes filled with cement, wood or
concrete and by-products arising from steel melting, heating, surface conditioning, grinding,
sawing, welding and torch cutting operations, such as slag, mill scale, baghouse dust, grinder
dust, sludge). In case of aluminium scrap, for some grades, other metals are desired to some
extent in order to produce the desired quality of aluminium alloy except for ferrous metals and
lead.
Limits for foreign materials are not generally defined, however some categories of EN 13920
include equivalent limits in the range from 2 5 %. A summary of limitations on foreign
materials is shown in Table 5.
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End-of-waste criteria
The scrap shall be free from attachment devices, steel core wires, coiling spools of any material,
bundling material and other components of electric lines other than aluminium cables and wires.
13920-3
The scrap shall not be coated and shall be free from burned wire, oil, grease, dust, plastics and any
other type of foreign material.
13920-4 The scrap shall be free from oil, grease, powder, plastics and any other type of foreign material.
The scrap shall not contain more than 5 % (mass fraction) of oil, grease, dust, plastics and any
13920-5 other type of foreign non-metallic material as a total. The scrap shall be free from foreign metallic
materials.
The scrap shall not contain more than 5 % (mass fraction) of oil, grease, dust, plastics, calcareous
13920-6 deposits and any other type of foreign non-metallic material as a total. The scrap shall be free
from pieces of alloys of the 2xxx or 7xxx series and free from foreign metallic materials.
The percentage of volatile substances shall not exceed 2 % (mass fraction). The total percentage
13920-7 of other non-metallic foreign material shall not exceed 2 % (mass fraction). The total percentage
of foreign metallic material, either free or attached, shall not exceed 2 % (mass fraction).
The sum of the percentages of oil, grease and other non-metallic materials in the scrap shall not
13920-9
exceed 2 % (mass fraction). The scrap shall be free from metallic foreign materials.
The scrap shall not contain more than 2 % (mass fraction) of moisture and not more than 5 %
(mass fraction) of total volatile substances. The scrap shall be free from any other foreign
13920-10
material, e.g. free iron and lead, and shall exclusively consist of beverage cans. It shall be free
from burnt or oxidized cans and aluminium foil.
The scrap shall consist of non-oxidized pieces free from moisture, oil, grease, dust, plastic, iron,
13920-11
brass and any other foreign material.
The scrap shall be unoxidized and the following tolerances apply to the delivered mass: 0.5 %
(mass fraction) of magnetic iron, 5 % (mass fraction) of moisture and oil, 3 % (mass fraction) of
13920-12
fines passing through a 20 mesh sieve (0.71 mm opening), after drying. The scrap shall not
contain any other foreign materials.
The scrap shall be unoxidized and the following tolerances apply to the delivered mass: 0.5 %
(mass fraction) of magnetic iron, 5 % (mass fraction) of moisture and oil, 3 % (mass fraction) of
13920-13
fines passing through a 20 mesh sieve (0.71 mm opening), after drying. The scrap shall not
contain any other foreign materials.
The scrap shall not contain free iron. The scrap shall not be heavily oxidized by the adopted
13920-15 decoating process. The scrap shall not contain fines less than 1mm in size and shall be free from
non-metallic materials.
The analysis of the content of foreign materials would have to be based on manual sorting of
non-metallic objects and particles. In the case of very fine particles (e.g. from WEEE), the
analysis by hand sorting may not be practically possible, therefore an alternative could be to
determine the metal yield. The metal yield analysis should be according to EN 13920-1:2002,
which is summarised and clarified below:
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End-of-waste criteria
Mass (m1)
(aluminium scrap sample input)
Mass (m2)
(after drying at 105oC and 360oC)
Mass (m3)
(after removal of free iron)
Mass (m4)
(after melting)
The analysis of the metal content would have to be based on the manual sorting of metallic and
non-metallic objects and particles. Non-metallic material adhering to metal objects would have
to be detached. The smaller the objects or particles, the more difficult such an analytical
procedure would be.
A limit on metal content is not proposed in the EN standard. Experts suggested metal content
limits in the range 90 98 % and a limit of 95 % is considered ambitious yet realistic.
The metal yield is usually lower than the metal content due to the other impurities being
included in the metal scrap (e.g. oxide, fine dirt attached to the scrap). The metal yield
according to standard EN 13920 varies from 80 90 % (except category 13920-14 scrap from
post-consumer aluminium packaging and 13920-16 scrap consisting of skimmings, drosses,
spills and metallic which have a lower metal yield). Based on the consultation with experts from
the technical working group, a metal yield limit value of 90 % could be considered equivalent to
a metal content limit value of 95 %.
The reason for this proposal is the practical feasibility of the measurement/testing.
27
End-of-waste criteria
Metal yield can be measured well for smaller particles or objects but it can be very hard or
practically impossible to obtain a representative laboratory sample from a mixture of large
objects.
Measuring foreign materials makes sense for larger objects that can be manually separated
without disproportionate efforts but makes less sense for smaller particles. It also has to be
considered that non-metallic materials adhering to the surface would potentially be much more
relevant for smaller particles.
It is proposed not to set a limit value on the metal content because the concept of foreign
materials as well as the value of the metal yield is already used by European standards EN
13920. The concept and measurement of foreign materials is practically equivalent to the
reverse of the concept of metal content. However, for metal content it is conceptually slightly
more complex than for foreign materials and therefore should be considered a second choice.
Furthermore, the scrap shall not contain excessive oxide in any form, except for typical amounts
arising from the outside storage of prepared scrap under normal atmospheric conditions. This
requirement is used in order to avoid the inclusion of metal scrap which will have a very low
economic value due to the excessive metals oxidation.
The scrap shall not contain excessive metal oxide in any form, except for typical amounts arising
from the outside storage of prepared scrap under normal atmospheric conditions.
The discussion of the TWG during the workshop in July 2009 in Seville led to the conclusion
that a qualitative requirement was sufficient in the sense that the aluminium scrap should be free
of visible oil. This means that oil, oily emulsions, grease, or lubricants in general should not be
visible in any part of the scrap load with special attention to the bottom of the scrap load where
the oil can be accumulated. Each load/consignment of scrap should be inspected visually
regarding this requirement, especially in those parts of the load where oil is most likely to
accumulate (the bottom).
An additional proposal of some of the TWG experts was to use the formulation of 'dripping oil'
instead of 'visible oil'. However, the criterion on dripping oil could cause confusion and would
require extra analysis. Another disadvantage is the increased environmental risk caused by a
higher content of oil compared to the definition of 'visible oil'. In order to guarantee the
appropriate quality of scrap without a negative environmental impact, 'visible oil' is the
preferable formulation.
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End-of-waste criteria
Oil, oily emulsions, lubricants or grease should not be visible in any part of the scrap load, except
negligible amounts that will not lead to any dripping. Visual inspection shall pay particular attention to
those parts of the load where oil is most likely (the bottom).
Radioactivity
The end-of-waste criteria need to address radioactivity because of the direct environmental and
health risks of incidents involving radioactive scrap. In addition, the financial consequences of
such incidents for the metal processing industry are always very serious, and the incidents can
lead to a loss of trust in the recycled metal industry and the associated products due to
unnecessary radiation emanating from consumer purchases.
It is very important to detect the presence of radioactive material as early as possible in the
supply chain and scrap with end-of-waste status must not show any detectable radioactivity
above background level ('background level' as defined in UNECE recommendations).
All scrap grades shall be checked as early as possible, preferably at the origin of the material
source when scrap enters the material chain, and in all subsequent stages of the scrap supply
chain, in strict compliance with state-of-the-art and most efficient detection equipment and
within the limitations of accessibility.
The technical working group strongly supported that the monitoring of aluminium scrap with
respect to radioactivity should be carried out in accordance with the UNECE Recommendations
on Monitoring and Response Procedures for Radioactive Metal Scrap(2) and that the scrap metal
should show no detectable radioactivity above background level.
More specifically, the radiation of each load of metal scrap shall be monitored in accordance
with the UNECE Recommendations and no radiation levels significantly in excess of natural
radiation background in the local area shall be detected. This should be demonstrated by the
owner of the scrap metal that declares compliance with the end-of-waste criteria, for example by
providing a Radioactivity Test Certificate in accordance with the UNECE Recommendations.
The test certificate has to be issued (or stamped) by the operator of the detection equipment,
which needs to be a reliable and qualified organisation/company.
The recommendations are intended to assist Governments, industry and all concerned parties to
counter the problem of radioactively contaminated scrap metal, activated scrap metal and scrap
metal with radioactive source(s) or substances contained within it (termed 'radioactive scrap
metal' []) by seeking to prevent its occurrence, by effectively monitoring metal shipments and
facilities, and by intercepting and managing any radioactive scrap metal that is detected. The
recommendations set out the responsibilities of all concerned parties and the actions required of
them to fulfil the objectives.
The owner or seller of the material that applies the end-of-waste criteria should arrange for
radiation monitoring to be performed on the scrap metal (each load or consignment) and to
provide a certificate indicating the results of that monitoring. (An example of a certificate of
shipment monitoring is attached as Annex 1 to the UNECE Recommendations.) The
owner/seller should ensure appropriate training of involved staff.
(2) http://www.unece.org/trans/radiation/docs/recommendations_e.pdf
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End-of-waste criteria
Ensure that incoming and outgoing shipments are checked by administrative and visual
means.
Provide radiation monitors at the entrance/exit to the premises and, as appropriate, on
conveyors and grapples. All entrances and exits should be monitored.
Ensure the effectiveness of the radiation monitors by appropriate quality assurance
procedures to verify the ability to detect changes in radiation intensity.
Arrange for periodic calibration and testing of the detectors (at least annually) to ensure
optimum performance.
Provide appropriate training in radiation monitoring and initial response procedures for
personnel likely to be involved in the monitoring of scrap metal shipments.
Establish a response plan for action in the event of radioactive material being discovered.
Make a formal arrangement with the national organisation with experience in radiation
monitoring and radiation protection to provide:
Require that contracts for the supply of scrap metal include the condition that any cost
associated with radioactive material discovered in shipments be accepted by the seller
unless the original owner of the radioactive source or material can be found.
Instruments for detecting radioactive material can be divided into three categories and any of
them could be used for measuring radioactivity:
Pocket-type instruments, which are small, lightweight instruments used to detect the
presence of radioactive material and to inform the user about radiation levels.
Hand-held instruments, which usually have greater sensitivity and can be used to detect,
locate or (for some types of instruments) identify radioactive material. Such instruments
may also be useful for making more accurate dose rate measurements in order to
determine radiation safety requirements.
Fixed, installed, automatic instruments, which are designed to be used at checkpoints.
Such instruments can provide high sensitivity monitoring of a continuous flow of vehicles
whilst minimising interference with the flow of traffic.
To demonstrate that the scrap has been checked, each consignment/shipment of scrap shall
be accompanied by a completed certificate according to Annex I of the 2006 UNECE
Recommendations on Monitoring and Response Procedures for Radioactive Scrap Metal or
an equivalent certificate according to national rules) (3)
This certificate shall be issued by the operator of the detection equipment.
(3) The certificate may be included in other documentation accompanying the consignment/shipment.
30
End-of-waste criteria
Certificates may be provided in electronic form. For multiple shipments to the same customer, and with
the agreement of the customer, a single certificate may be supplied to demonstrate that all loads have
been monitored.
Hazardous properties
Condition (d) of Article 6 of the WFD demands that end-of-waste criteria need to ensure that the
use (understood here as including also transport, handling, trade) of scrap shall not lead to
overall adverse environmental or human health impact.
This implies that aluminium scrap should not obtain end-of-waste status if it has any of the
hazardous properties included in Annex III of the WFD (properties of waste which render it
hazardous).It is understood for example that asbestos should not be included in end-of-waste
scrap.
The reason is that in this case, general waste regulatory controls as well as the specific
provisions of the WFD on hazardous waste (in particular Articles 17 to19 regarding control, ban
on the mixing and labelling of hazardous waste) are needed to protect the environment and
human health.
Comprehensive direct monitoring of the 'product' regarding all of the possible hazardous
properties by specific tests is, however, not a feasible approach. The best approach to exclude
hazardous properties of the product, is to rely on a combination of requirements on input
materials, treatment processes and techniques, and quality assurance. (These requirements are
presented in the following sections further below.)
Nevertheless, it has been suggested to also include in the product quality requirement a clause
that clearly establishes that scrap with hazardous properties does not cease to be waste. This is
needed not only to establish clarity in principle but has also a practical value in cases when
certain types of hazardous properties are detected as part of a visual inspection, especially when
hazardous criteria are further harmonised within the EU (e.g. ecotoxicity, leachate criteria).
A particular aspect that should also be addressed is pressurised, closed or insufficiently open
containers of all origins. Such containers represent a specific hazard because they could cause
explosions in the metalwork furnace. This hazard is not addressed explicitly by Annex III of the
WFD. A specific clause would therefore have to be included in the end-of-waste criteria.
The scrap does not contain any pressurised, closed or insufficiently open containers of any origin
that could cause explosions in a furnace.
The relevant standards or industry specifications are those for direct input to one of the final
uses (the production of metal substances or objects by smelters/refinery/foundries). The
standards or specifications used may be of an agreed upon nature across an industry sector (e.g.
EN 13920, ISRI) or may be defined by one or more individual final use companies.
The TWG has advised against demanding strict compliance with a closed list of grades,
standards or specifications. Reasons are that the specifications are a matter of commercial
transaction rather than a regulatory means and that the monitoring would be very burdensome
31
End-of-waste criteria
and that the details of specifications are very greatly, for example across countries and
individual user firms.
The TWG also advised against obliging the metal scrap supplier to produce proof that the
graded scrap will actually be accepted by a user (e.g. by systematically producing commercial
contracts). This was deemed too burdensome and disproportionate.
The scrap categories of the EN 13920:2002 (except EN 13920-14, 13920-16), the ISRI
classifications or classifications used for aluminium product will generally be acceptable.
The specifications used may be of an agreed upon nature across an industry sector (e.g. EN 13920,
ISRI specification) or may be defined by one or more individual final use companies.
Dimension
According to the EN 13920 the scrap shall not contain objects of a dimension that does not fit
into a metalwork furnace (i.e. generally not greater than 600mm 600mm 400mm). The
dimension is related to the technical limitation of the process and does not have a direct effect
on environmental or health issues. Therefore, the size limitation need not be included as one of
the criteria and can remain a matter for the specifications and commercial agreements between
the seller and buyer.
32
End-of-waste criteria
The end-of-waste criteria should allow as input only waste types for which it is practical to
obtain aluminium scrap in compliance with the product quality requirements. This implies that a
waste can only be allowed if it contains aluminium metals that can be recovered for the
production of new aluminium products and, after appropriate treatment, can be used without
overall adverse environmental or human health impacts.
The discussion in the TWG showed that the criteria on input materials should not be
unnecessarily restrictive and that, in principle, all types of waste that contain recoverable
aluminium scrap and for which treatments exist to obtain scrap metal with the required product
quality should be allowed as input. The technical working group suggested that the criteria on
input materials and treatment processes be explicit for those wastes that pose relevant hazards
and that the criteria be more general for other types of wastes.
It was pointed out during the discussion with the TWG, that an approach based on a 'positive
list' of allowed waste input materials held the risk of 'omitting' suitable wastes, or excluding
waste which becomes suitable as new treatments become available. It was also pointed out that
assigning a waste to a category under the European Waste List per se does not give any
guarantees on the nature and suitability of that waste. (The waste categories listed in Table 1 are
examples of wastes which may contain metal that can be recovered.) Basing the criteria on a
negative list of unsuitable input materials would imply a high risk of 'forgetting' to exclude
unsuitable waste types. However, it should be clear that no mixing with other wastes (i.e. wastes
that do not contain recoverable aluminium) are allowed.
Hazardous wastes pose substantial risks to the environment and human health. Waste law
includes specific regulatory controls to deal with these risks. A hazardous waste can only cease
to be waste if it can be established that it has been treated in a way that reliably removes all
hazardous properties.
The monitoring and testing of product quality alone is not a workable approach to ensure that
the resulting product does not have any hazardous properties as sufficient confidence could only
be obtained with disproportionate testing efforts. Instead, the monitoring of product quality
should be complemented by controlling that whenever a hazardous waste is used as an input, it
has undergone a suitable treatment. Which type of treatment is suitable depends on the type of
hazardous waste used as input.
As part of end-of-waste criteria, the choice of suitable treatment to deal with hazardous waste
cannot be left open to case-by-case industry decisions but must follow clearly defined and
legitimated treatment requirements for the specific type of hazardous waste. In the EU, such
treatment requirements have been established in the ELV Directive and the WEEE Directive.
Hazardous wastes that are covered by the provisions of one of these Directives could therefore
be allowed as input materials.
33
End-of-waste criteria
Further types of hazardous waste could be allowed as input at a later stage if their treatment is
legally regulated in an equivalent manner.
An alternative approach, which would prevent the need for updates of the end-of-waste criteria,
would be to generally allow hazardous waste as input material under the condition that proof be
provided and approved by the authorities (for example as part of the permit for the waste
treatment facility) that suitable treatment has been applied to remove all hazardous properties.
No hazardous waste shall have been used as input to obtain the scrap except:
wastes that are covered by the WEEE Directive or the ELV Directive; and
discarded equipment containing chlorofluorocarbons that does not have any hazardous
properties except those due to the chlorofluorocarbon content;
other hazardous waste for which proof is provided that suitable treatment to remove all
hazardous properties has been applied in a treatment process which is approved by
authorities.
When reaching end-of-waste status, the material must have gone through all necessary treatment
processes that make it suitable as direct input material for the final users of scrap and allow for
transporting, handling, trading and using the scrap without increased environmental and health
impacts or risks.
The required treatment processes to achieve this differ depending on the waste types from which
the scrap has originally been obtained. Some details on the treatment processes and techniques
for different types of waste are described in Chapter 1.3.
The metal scrap case study in the JRC End-of-Waste Criteria report suggested process
requirements according to the three groups of scrap sources, however further considerations
showed that the system of grouping is not essential in order to propose the criteria.
basic general process requirements that apply in all cases (for all types of waste);
specific process requirements for specific types of waste (including all allowed hazardous
waste types).
This reflects the discussions in the technical working group, which showed that for non-
hazardous waste, there is a preference for generic requirements that do not prescribe a specific
technology. The reason is that industry should not be prevented from adapting to the specific
circumstances or from innovation. Specific process requirements are however needed for the
34
End-of-waste criteria
treatment of hazardous wastes and certain complex waste and possibly also for certain special
cases of input materials (such as turnings or cables) for which the direct product requirements
are considered not stringent enough.
The general process requirements clarify the minimum treatment required and where in the
treatment chain the point of end-of-waste is reached. The principle is that scrap should have
completed all requirement treatment that makes it suitable for direct use in the production of
new metal. Excepted from this are only pre-treatments that normally take place directly at the
refiner/remelter. Some scrap may be obtained in pure form by segregating it from other waste at
source or during collection. Any other wastes (that at the origin contain aluminium scrap and
other material) must have been treated to separate the non-metal and if needed also other metals.
ELV and WEEE are complex wastes for which treatment requirements have been established by
European Directives. The wastes covered by these Directives, whether hazardous or non-
hazardous, can not cease to be waste unless they have fulfilled the provisions of the Directives.
Specific treatment requirements are also needed for discarded equipment containing
chlorofluorocarbons because they are hazardous waste and not in all cases covered by the
requirements of the ELV or WEEE Directives.
If filings and turnings are allowed as input materials, special treatment requirements are needed
for the removal of cutting fluids such as oil because the related qualitative product quality
requirement alone may not be stringent enough for this particular kind of waste.
Requirements of how to treat cables and containers can be seen as optional as a reinforcement of
the set of criteria. To some extent, the relevant issues are already addressed by the product
quality requirements.
There was a broad consensus in the technical working group that there should be no
requirements on baling or compacting, as this might be counterproductive (e.g. hiding of bad
material inside bales).
All mechanical treatment (like cutting, shearing, shredding or granulating; sorting, separation,
cleaning, de-polluting, emptying) needed to prepare the material for direct input into final use shall
have been completed.
a. Input materials that originate from end-of-life vehicles or waste electronic or electric
equipment shall have completed all treatments as required by the ELV Directive (Article 6)
and the WEEE Directive (Article 6).
b. Discarded equipment containing chlorofluorocarbons (CFCs) must have been captured in an
approved process.
c. Filings and turnings that contain cutting fluids such as oils shall have been treated to remove
these fluids by processes like centrifugation or pressing.
d. Cables must have been stripped or granulated. If a cable contains organic coatings (plastics),
the organic coatings must have been removed according to the best available techniques.
e. Barrels and containers including inter alia oil and paint drums, shall have been emptied and
cleaned.
f. Hazardous substances shall have been efficiently removed.
35
End-of-waste criteria
a. the name or code of the scrap category according to a specific product standard or
specification and a declaration of compliance with the standard or specification;
b. a radioactivity test certificate in accordance with the UNECE Recommendations on
Monitoring and Response Procedures for Radioactive Scrap Metal or similar certificate
according to national rules;
c. identification of the external verifier or the certification of the quality assurance system;
d. statement of conformity to the end-of-waste criteria;
e. whether or not the scrap complies with the limit for foreign materials or metal yield.
A quality management system must be in place and cover the key areas of operation where
compliance with end-of-waste criteria will have to be demonstrated.
It is considered appropriate and proportional for the end-of-waste criteria to require that a
quality management system be implemented and externally verified. Such verification should
assess if the quality management system is suitable for the purpose of demonstrating
compliance with the end-of-waste criteria applicable to the case in question.
36
End-of-waste criteria
The competent waste authority must be able to commission an independent second party audit
of the implemented quality management system to satisfy itself that the system is suitable for
the purpose of demonstrating compliance with end-of-waste criteria.
The detail on the verification, auditing or inspection of the quality assurance system can follow
different national approaches.
The quality management system must at least include the following elements:
1. the quality management system must be auditable and ready for inspection by the competent
authority under waste law to ensure that the system is suitable for the purpose of
demonstrating compliance with end-of-waste criteria;
2. must include a set of documented procedures addressing each key process relevant to
compliance with the technical end-of-waste criteria, including:
By means of representative sampling of consignments the monitoring shall also include testing of
compliance with the limit value regarding the foreign materials or the metal yield.
The appropriate frequencies of sampling shall be established by consideration of the following factors:
The process of determining monitoring frequencies should be documented as part of the overall quality
assurance scheme and as such should be available for auditing.
37
End-of-waste criteria
It is also understood that aluminium scrap that does not meet the end-of-waste criteria can still
be used for the production of secondary aluminium. In this case, the recycling or recovery is
completed when the scrap is melted in a furnace and new metal has been produced. The new
metal will not be considered waste.
The end-of-waste criteria including proposed systems of monitoring with explanations are
summarised in Annex 3.
38
Impacts
3 IMPACTS
In order to evaluate the soundness of end-of-waste criteria developed for scrap, it is necessary to
assess the possible impacts of removing the waste status from these materials. The impact
assessment covers environmental, economic and legal impacts that may result once the scrap
ceases to be waste. Many Member States have different operational rules and permits used for
waste handling. As a result, since there are different existing approaches, the impact of end-of-
waste would be different from country to country.
Also the specific air emission from the aluminium production in the EU are not expected to
change because the relevant processes and flue-gas treatments (under IPPC permits) will not be
affected.
It is unlikely that facilitated export of end-of-waste scrap outside the EU would have any
substantial effect on air emissions of aluminium production outside the EU. Because of the strict
product quality requirements, it can be expected that exported end-of-waste scrap will on
average not be more polluted than the scrap used today for aluminium production outside the
EU (notably the possible amounts of coatings present will be very limited by the limit value on
foreign materials/metal yield and PVC limitation). An increase in air emissions should therefore
not be expected.
39
Impacts
Shipment
The waste status of metal scrap affects the exportability by increasing the administrative and
economic burdens. The costs to the recycling sector in the wider sense are higher under the
waste regime. The total involved costs related to international shipment are difficult to estimate,
however the European Ferrous Recovery and Recycling Association (EFR) and The British
Metals Recycling Association (BMRA) gave practical examples of possible complications due
to the 'waste' status of scrap metal and these are given below.
With end-of-waste status, it would be possible to produce the necessary evidence based on the
end-of-waste criteria concept, rather than having to track the material through the docks and
across the world. According to one large UK metal recycling company, the costs in 2007
associated with obtaining this information from around 200 facilities was GBP 100 000. This
figure includes administrative and translation (of supporting documents/licences) costs.
Notification and insurance costs on financial guarantees for waste shipments sent to
countries where pre-notification is required (including certain green list shipments)
under the Waste Shipments Regulations.
Each notification requires a financial guarantee, except to countries under treaty of accession
arrangements. Several Dutch companies at one time have had a total of up to EUR 10 million
tied up in financial guarantees. This is financed by the bank at certain costs and also means a
lesser liquidity for the companies. Because of this there is a limit to the number of notifications
a company can handle/absorb. In other words, there is an artificial (trade) barrier and
companies can not sell to all potential customers after their financial limit has been reached.
Also in the UK, the cost of a single notifiable ship has been qualified as high, plus insurance
premiums on a financial guarantee (typically several thousand pounds).The shipment of green
listed wastes to EU Member States with transitional period do not require a financial guarantee
(insurance). However, administrative fees for notification might be high and vary from country
to country. End-of-waste would facilitate the free trade of scrap that meets the set end-of-waste
conditions and criteria where there are metal works in Latvia up to 31 December 2010; Poland
up to 31 December 2012; Slovakia up to 31 December 2011; Bulgaria up to 31 December 2014;
and Romania up to 31 December 2015.
Administration costs for maintaining Annex VII Waste Shipments Regulation tracking
forms and domestic waste movement forms.
In addition to the direct administration costs associated with form filling, there is an issue of
having to supply commercially sensitive data. The British Metals Steel Association received
evidence that companies have lost customers due to this requirement. Customers outside the EU
jurisdiction are not willing to have their commercial transactions recorded and made available to
public authorities. Therefore they turn to non-EU suppliers, such as exporters from the US,
Russia or Japan.
40
Impacts
The Waste Shipment Regulations require that non-OECD countries reply to the Commissions
note verbale, indicating which wastes they are prepared to accept and what control
procedures they wish to apply. If they do not reply (and very many do not or give a negative
reply for waste from the EU, whilst they import scrap from elsewhere but do not consider such
metal scrap to be waste), then notification controls apply by default. In these circumstances,
either: the business incurs the additional costs of notification; or since notification
documentation from the receiving country is difficult and time-consuming to obtain, in the
meantime the buyer may turn to a non-EU supplier. On average the notification procedure takes
3 to 6 months. Where notifications are not required, the current waste status may still affect
exportability in terms of the waiting time for buyers to receive import licenses. As price and
demand change quickly, these waiting times lead to market distortions and inefficiency.
Evidence from published notifications show, despite the cost, that non-hazardous waste are
exported under such costly controls that were not originally intended to be applied to non-
hazardous wastes at all. Industry absorbs the costs and regulatory relief is sought to reduce
costs.
A number of Member States allow waste to cross only at designated border crossings which
restricts transport routes. The recycling sector explained that it worked with the Council and
Commission Regulations (EC) No 1420/1999 and No 1547/1999 from 1998 to 2006 to obtain
well over a dozen amendments to keep recyclables flowing to customers in non-OECD
countries. However, due to the response or lack of response of certain non-OECD countries
those secondary metal markets are instead fed for example by the USA. However, comparison
of the exports of the USA (where scrap is not waste) with exports of the EU (where scrap is
waste), since there is a great overlap of the major trading partners, reinforces that the markets
will adjust and flows may change slightly, but no great market changes would be forecast on the
end-of-waste of the EU. Furthermore, end-of-waste criteria may not affect how importing
countries view EU-origin scrap. For example: the Chinese CCIC pre-inspections use their own
parameters to accept or refuse shipments regardless of EU terminology; and the Indian port
authorities inspect according to their own regulations.
It has also been mentioned that a number of Member States are now asking for pre-notification
for non-hazardous green list wastes, e.g. scrap shipments to other EU Member States.
In a Waste Treatment Authorisation, a scrap company may have to complete the administration
paperwork indicated below every year:
41
Impacts
Most companies that are active in the export market have specialized staff for environmental
issues. The waste status/legislation is the main reason for this as well as the necessity for quality
management because of the strict legislation. On average, a staff will consist of 1 to 5 persons
depending on the size of the company. In the Netherlands such a staff will represent a cost of
anywhere between EUR 50 250 000 in costs. This can, however, be much higher for larger
companies.
The considered estimate of the administrative burden associated with the legislative
requirements of handling of scrap metal as a waste material may have had a cost in the region of
GBP 262 885 in 2008 for one major company in the EU.
When aluminium scrap cease to be waste according to Article 6 of the WFD, the exemption
under Article 2.2 of the REACH Regulation no longer applies. A benefit of EU-wide end-of-
waste criteria will therefore be to clarify when aluminium scrap has to be considered a
substance, mixture or article under REACH and when not.
However, concerns have been raised that the end-of-waste criteria may lead to disproportionate
regulatory burdens under REACH, especially for the companies that produce aluminium scrap
with end-of-waste status. The main potential burdens are related to the registration of the
substances in end-of-waste scrap and to the obligations to provide safety information to
downstream users.
(4) EC 1907/2006.
42
Impacts
Under REACH, pure metal (even if containing a certain amount of impurities) is considered as
a substance. Recovered pure metal (even if containing a certain amount of impurities) is also a
substance. Registration requirements for the substance will depend on whether the substance
has been registered before and the relevant safety information is available (see Article 2 (7)(d))
of REACH.
Alloys are considered as (special) preparations(5) and the substances in those preparations are
subject to registration. Recovered metal made from mixed alloy metal scrap will normally be a
preparation but it could in certain cases also be a substance with impurities (e.g. when the
purpose of recovery is only to reclaim one main metal and all other constituents can be seen as
impurities). In general, all components which have been intentionally selected for recovery and
which have a main function in the recovered material should be seen as separate substances
(e.g. steel will next to iron normally always contain manganese; the recycled steel is therefore a
preparation). Constituents which only occasionally occur in parts of the waste from which the
recovered metal originates or which do not have a particular function in the recovered material
can be seen as impurities (e.g. molybdenum may occur in certain types of steel but not in
others).
The CA/24/2008 rev.3 document states the following on impurities (in general terms on waste
and recovered substances):
Recovered substances may contain impurities which may distinguish them from corresponding
materials not deriving from recovery processes. This is in particular the case when recovered
materials contain unintended constituents which have no function for the recovered material
and the only reason for their presence in the recovered material is that they were part of the
input waste for the recovery process. The content and nature of such unintended constituents
may vary significantly from batch to batch (e.g. in time and location). Full knowledge of the
exact composition in each such case may require substantial analytical efforts. While such
constituents may have originally been intentionally added as substances to form a preparation,
their presence in the recovered material may be unintended (depending on whether these
constituents have a specific function or not) and therefore, they can be considered as impurities,
which do not require separate registration.
During the mechanical separation of mixed waste it is often impossible to reach 100 % purity
free of alien elements. These alien elements often are either extraneous to the waste stream per
se (for example, and depending on the waste stream, stones, plastics, pieces of rubber, sand,
etc.) or extraneous to the material object of the recovery but part of the final product that
became waste (for example, paints, coatings, etc.), of which the composition and total amount
are difficult to precise. After appropriate sorting and separation, these fractions should be
present in the recovered material only in very small fractions. In this case, such elements can be
considered as impurities that do not need to be registered.
(5) The term preparation has meanwhile been superseded by the term mixture.
43
Impacts
Even if impurities do not have to be registered separately, they may be relevant for the hazard
profile as well as the classification and labelling of the substance or mixture in which they
occur. Relevant risk management measures may need to be recommended in SDS or
information according to Art. 32. These risk management measures can consist e.g. in further
purification steps to eliminate impurities or measures to ensure the safe handling of the
substance with the impurities in it.
Note: Producers of scrap applying the end-of-waste status (as manufacturers) have the
obligation under REACH to decide which of the above two cases applies. This rather short
summary should not prevent recyclers from reading and using the guidance for substance
identification (available in ECHA web pages).
To understand which substances, as defined by REACH, there are in aluminium scrap with end-
of-waste status, the following technological aspects given below need to be considered.
Aluminium scrap with end-of-waste status would:
a. always contain aluminium as a component that has been intentionally selected for
recovery and that has a main function in the recovered material.
b. sometimes contain other components that have been intentionally selected for recovery
and that have a main function in the recovered materials, for example silicon or copper in
certain cast aluminium scrap.
c. always contain small amounts of elements that do not have a particular function in the
recovered material. These elements may be metals or non-metals, which occasionally
occur in parts of the waste from which the recovered material originates. (The proposed
end-of-waste criteria limit the possible total content of foreign components to about 5 %
by weight and exclude any aluminium scrap that has hazardous properties included in
Annex III of the Waste Framework Directive.)
From these considerations, it follows that aluminium scrap with end-of-waste status can often
be considered a mixture under REACH which contains several metals. The components
mentioned under a) and b) above, for example, can be considered substances under REACH.
More specifically, they can be considered recovered substances. The elements mentioned under
c) can be considered impurities that need not be registered. Irrespective of whether those
impurities are original impurities of the substance or whether they are steriles in the metal scrap,
they will need to be allocated as impurities of the substance(s) in the mixture. This is needed if
44
Impacts
there are impurities that are relevant in terms of the naming of the substances and the sameness
question for the purposes of the application of Article 2(7)(d).(6)
As the following assessment will show, it can be expected that these conditions can normally be
met without disproportionate efforts. This implies that in practice, processors will not have to
register any substances under REACH. Industry associations can contribute decisively to keep
the burden low for companies that want to demonstrate compliance with these conditions.
Under REACH, recovered aluminium scrap can be considered either a single recovered
substance (aluminium) or a mixture containing various recovered substances (aluminium and
other alloying metals).
Wrought aluminium scrap meeting the end-of-waste criteria could often be considered a
substance (aluminium). All other constituents would qualify as impurities, should the scrap not
have been selected for their presence.
Cast aluminium scrap will, in most cases, consist of alloyed metal and therefore contains further
metals with a function such as copper, silicon, iron or manganese. They would have to be
considered substances subject to registration under REACH.
The meeting on 14 October in Brussels revealed that aluminium and the other main metals used
in aluminium alloys will be registered by the December 2010 deadline. Metals used only for
special and rarer alloys may be manufactured and imported in lower quantities so that
registration may happen according to later deadlines. In any case, industry representatives
expect that these metals also be registered by the time producers of aluminium scrap with end-
of-waste status are faced with the need to apply the Article 2(7)(d) exemption.
In summary, industry expects that all relevant substances in metal scrap will be registered when
this is needed for the application of the exemption under Article 2(7)(d).(7)
Sameness
The CA document 24/2008/rev3 explains that in assessing whether the recovered substance is
the same as a substance that has already been registered or whether the substances are different,
recovery installations need to apply the rules of the guidance on substance identification and the
guidance on data sharing.
The CA document notes that variations in the composition and the impurity profile, including a
variation in the percentage of impurities, do not necessarily mean that substances are different.
According to the guidance on data sharing, for substances with a well-defined composition (i.e.
mono-constituent and multi-constituents substances) the sameness of the naming is in principle
(6) Failing this, the scrap metal as a whole would be seen as one substance and hence could be subject to registration.
(7) This assumes that the end-of-waste criteria will not enter into force until December 2010.
45
Impacts
sufficient to be able to share data even though certain impurities might lead to a different
classification/hazard profile. Only in cases where all data is clearly not suitable for the other
substance these substances can be regarded as different (e.g. in case of very different physical
properties which have essential impact on the hazard properties, like water solubility).
It should be noted that the possible amounts and variation of impurities are limited by the end-
of-waste criteria. Aluminium scrap that complies with the end-of-waste criteria will contain
only very limited amounts of substances other than aluminium and other metals. This will be
ensured by the end-of-waste criteria by limiting the content of foreign materials and by the
process requirements. Foreign materials that would change the hazardous properties of the
recovered metal scrap are excluded by the end-of-waste criteria. This facilitates considering the
metals contained in aluminium scrap to be the same substances as the substances produced by
the producers of aluminium and the other metals.
In this context it is useful to highlight again that impurities (whether from original impurities of
the substance or from foreign materials in the metal scrap) will need to be allocated as
impurities of the substance(s) registered and identified in the metal scrap as subject to
registration. This is needed in terms of the naming of the substance and the sameness for the
purposes of the application of Article 2(7)(d). Failing this, the scrap metal as a whole would be
seen as one substance, which could mean that identifying sameness with the registered
substance could be more difficult.
The responsibility for determining sameness lies in the hands of the producers of aluminium
scrap that apply the end-of-waste status as the manufacturers of the substances.(8) There is no
confirmation given on sameness by the European Chemicals Agency. The manufacturer will
need to have information on the substance itself and its impurities(9).
European recycling industry associations have announced that they will prepare standard
documents with the necessary information (including the chemical composition of the different
scrap categories) and guidance that will allow individual companies to decide about the
sameness of substances. The guidance may also explain how to allocate any impurities in
mixtures to the individual substances. It is therefore not expected that individual companies will
have to carry any testing or chemical analysis in order to demonstrate the sameness of the
substances.
Article 32 information will be sufficient for most of the other substances that may appear in
aluminium scrap. The information required under Article 32 (i.e. if no safety data sheet is
required) is rather limited (registration number, information on authorisation and restriction if
(8) As stated in the CA document 24/2008/rev.2 on Waste and recovered substances: [] all forms of recovery are
[] considered as a manufacturing process whenever, after having undergone one or several recovery steps, they
result in the generation of one or several substances that have ceased to be waste.
(9) If the manufacturer has pre-registered the substance, discussions within the SIEFs will allow companies to address
sameness and refine and if necessary correct substance identity, as long as it is clear that the pre-registration was done
for the concerned substance.
46
Impacts
any, and any other available and relevant information to enable appropriate risk management
measures).
Industry associations have expressed that they will prepare standard information for their
members. Having access to such standard information will allow individual companies to show
that the required information under Article 2(7)(d) is available to the establishment undertaking
the recovery.
Imports
The exemptions under Article 2(7)(d) apply only to substances which are recovered in the
Community. It should be noted that Recital 22 of the WFD says that for the purposes of
reaching end-of-waste status, a recovery operation may be as simple as the checking of waste to
verify that it fulfils the end-of-waste criteria. If the waste is checked to verify that it fulfils the
end-of-waste criteria after it has been imported in the Community and not before, then it would
have waste status when it is imported and it seems logical then to consider that the substances it
contains are recovered in the Community.
1. An SDS, including where relevant (>10 t/yr) exposure scenarios, must be provided when:
2. The supplier shall provide the recipient at his request with a SDS where mixtures do
not meet the criteria for classification as dangerous but contains an individual
concentration of 0.1 % by weight for non-gaseous mixtures at least one substance that is
PBT or vPvB in accordance with the criteria set out in Annex XIII or has been included in
the list established in accordance with Article 59(1) or a substance for which there are
Community workplace exposure limits (Article 31(3)).
47
Impacts
Such information should be provided free of charge and at the time of delivery (Article 32(2)).
The information should be updated in cases where new information on hazards or risk
management measures are available or in cases where the substance is subject to authorisation
or restriction (Article 32(3)).
The end-of-waste criteria will, however, allow metals contained in metal scrap even if they are
dangerous substances, and an SDS may be required in such a case.
A producer of aluminium scrap that applies the end-of-waste status does not have to generate a
chemical safety report or exposure scenario for a substance (or substance in a mixture) that is
exempted from registration (under Article 2(7)(d). The same safety information that must be
available to fulfil the condition under Article 2(7)(d)(ii) can usually be used for communicating
the information down the supply chain.
The information required under Article 32, i.e. if no SDS is required, will be limited to any
other available and relevant information to enable appropriate risk management measures. For
recovered substances that have not been registered (Article 2(7)(d) exemption), no registration
numbers or information on authorisation or restriction have to be supplied.
Such standard documents should cover all relevant (downstream) uses of the scrap. The
standard documents should consider fully any guidance developed by ECHA on this issue in
order to ensure the acceptance by the competent authorities of information provided by
individual suppliers according to the standard documents.
48
Impacts
The same safety information that must be available to fulfil the condition under Article
2(7)(d)(ii) can be used for communicating the information down the supply chain. (It is
understood that this applies also to the exposure scenarios, if these are required for a substance.)
49
Conclusions
4 CONCLUSIONS
Thanks to the strong support from the TWG, it has been possible to develop proposals for end-
of-waste criteria for aluminium scrap that:
are in compliance with all the conditions given by Article 6 of the Waste Framework
Directive;
would be operational in practice; and
would deliver clear benefits.
The main concerns that were raised, to different degrees by different experts and stakeholders,
were about the implications and possible burdens under REACH. An in-depth assessment of the
impacts related to REACH was carried out and has shown that REACH allows solutions so that
disproportionate burdens for the industries can be avoided.
It can be expected that recycling markets will benefit strongly from harmonised, EU-wide
end-of-waste criteria for aluminium scrap.
There is a clear need for Community-wide end-of-waste criteria for aluminium scrap.
Aluminium scrap represents one of the major material recycling flows and is traded across the
EU and worldwide. Under the old Waste Framework Directive and the corresponding case law
aluminium scrap was considered waste until it was melted in a furnace for the production of
new metal. The new Waste Framework Directive introduced the concept of end-of-waste status
and the possibility to develop end-of-waste criteria at the community level. Where end-of-waste
have not been set at the Community level, Member States may decide case by case whether
certain waste has ceased to be waste, taking into account the applicable case law. However,
many experts and stakeholders believe that case-by-case decisions are not desirable for
materials that are traded internationally in substantial amounts and that Community-wide end-
of-waste criteria are needed in such cases for the good functioning of the internal market and
also for the protection of the environment and human health.
'Early end-of-waste allows for reducing administrative burden and compliance costs.
Most of the experts in the TWG have supported the early end-of-waste approach, i.e. that
aluminium scrap may cease to be waste when it has been mechanically processed and has
obtained a sufficient quality that regulatory controls under waste regulation are no longer
needed to protect the environment and human health. A direct advantage, compared to late end-
of-waste as under the old Waste Framework Directive, is that the administrative burden and
paperwork under the waste regulation will be eliminated for compliant material. Such an
advantage weighs especially high when scrap demand in Europe is relatively weak and prices
are lower, such as in times of economic crisis.
The end-of-waste criteria allow for consolidating the status of compliant aluminium scrap
as high-quality secondary raw-material.
The proposed end-of-waste criteria imply reinforcing the quality assurance for aluminium scrap.
This will further improve its reliability as high quality raw-material and strengthen consumer
confidence in the product.
Disproportionate burden under REACH is avoidable, but support by the different industry
associations, guidance by the relevant European bodies and as much legal certainty as
possible are needed.
The main concerns regarding early end-of-waste for aluminium scrap are related to REACH
and the fact that the general exemption of waste from most obligations under the REACH
Regulation will not apply to scrap with end-of-waste status. The REACH impact assessment has
51
Conclusions
shown that it is possible for individual companies to avoid excessive burden under REACH.
However, uncertainties remain, notably about the guidance that will be provided by industry
associations and its acceptance by the authorities. Furthermore, under current law, registration
would be required for scrap that is imported to the Community under end-of-waste status. How
widely the end-of-waste criteria for aluminium scrap will be accepted, will to a large extent
depend on the degree of legal certainty that can be established about the obligations and non-
obligations under REACH.
Guidance by the relevant European bodies could make an important contribution in this sense. It
is also notable that during the intensive discussion of the REACH implications of end-of-waste
for aluminium scrap, no opinions were expressed that registration of the substances in the scrap
was required to fulfil the objectives of REACH. Instead, the discussions were characterised by
attempts to find a solution to the REACH problem. There seems therefore to be a case for
considering a legal exemption of end-of-waste scrap from registration obligations. Such an
assessment is, however, clearly not within the scope of this report.
52
References
5 REFERENCES
BIR, Report on the environmental benefits of recycling, 2008
Commission document CA/24/2008 rev.3, which was produced as a follow up to the 5th
Meeting of the Competent Authorities for the implementation of Regulation (EC) 1907/2006
(REACH)
Directive on Batteries and Accumulators, Directive 2006/66/EC of the European Parliament and
of the Council of 6 September 2006 on batteries and accumulators and waste batteries and
accumulators and repealing Directive 91/157/EEC
Directive 96/29/Euratom laying down basic safety standards for the protection of the health of
workers and the general public against the dangers arising from ionizing radiation.
ELV Directive; Directive 2000/53/EC of the European Parliament and of the Council on end-of
life vehicles, 2000
ISRI specification, Scrap Specification Circular, Institute of Scrap Recycling Industries, Inc.,
2008
REACH Regulation, Regulation (EC) No 1907/2006 of the European Parliament and of the
Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and
repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94
as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC,
93/105/EC and 2000/21/EC
53
References
Waste Shipment Regulation, Regulation (EC) No 1013/2006 of the European Parliament and of
the Council on shipments of waste
WEEE Directive, Directive 2002/96/EC of the European Parliament and of the Council of 27
January 2003 on waste electrical and electronic equipment (WEEE)
54
Annexes
ANNEXES
55
Annex 1
d 13920-5 (Scrap consisting of two or more wrought alloys of the same series)
Metal yield shall be 88 %. Composition (mass fraction) differs for different basis (multi-
purpose base, basis for 2xxx series, basis for 3xxx series, basis for 5xxx series, basis for
6xxx series and basis for 7xxx series).
56
Annex 1
Metal yield shall be 90 %. The scrap shall be unoxidised and the following tolerances
apply to the delivered mass: 0.5 %(mass fraction) of magnetic iron; 5 % (mass fraction) of
moisture and oil; 3 %(mass fraction) of fines passing through a 20 mesh sieve, after drying.
(10) This scrap category should not be accepted for end-of-waste due to the low metal yield.
57
Annex 2
58
Annex 3
59
Annex 3
Mass (m1)
(aluminium scrap sample input)
Mass (m2)
(after drying at 105 C and 360 C)
Mass (m3)
(after removal of free iron)
Mass (m4)
(after melting)
Oil, oily emulsion, lubricants or grease Visual inspection of each consignment by Oil, oily emulsion, lubricants or grease
Scrap shall be free of visible oil, oily emulsion, qualified staff should not be visible in any part of the scrap
lubricants or grease load, except negligible amounts that will not
lead to any dripping. Visual inspection shall
pay particular attention to those parts of the
60
Annex 3
61
Annex 3
Specific requirements:
62
Annex 3
63
Annex 3
64
Annex 3
65
European Commission
EUR 24396 EN Joint Research Centre Institute for Prospective Technological Studies
Title: End-of-waste Criteria for Aluminium and Aluminium Alloy Scrap: Technical Proposals
Authors: Lenka Muchov and Peter Eder
Luxembourg: Publications Office of the European Union
2010
EUR Scientific and Technical Research series ISSN 1018-5593
ISBN 978-92-79-15990-9
doi:10.2791/43228
Abstract
This report is the JRC-IPTS contribution to the development of the end-of-waste criteria for aluminium scrap in
accordance with Article 6 of Directive 2008/98/EC of the European Parliament and of the Council on waste (the
Waste Framework Directive).
This report includes a possible set of end-of-waste criteria and shows how the proposals were developed based
on a comprehensive techno-economic analysis of aluminium and aluminium alloy recycling and an analysis of
the economic, environmental and legal impacts when aluminium scrap cease to be wastes. The purpose of end-
of-waste criteria is to avoid confusion about the waste definition and to clarify when certain waste that has
undergone recovery ceases to be waste. Recycling should be supported by creating legal certainty and an
equal level playing field and by removing unnecessary administrative burdens. The end-of-waste criteria should
provide a high level of environmental protection and an environmental and economic benefit.
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