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De Tandt E, Demuytere C, Van Asbroeck E, Moerman H, Mys N, Vyncke G, Delva L, Vermeulen A, Ragaert P, De Meester S, Ragaert K. A recycler's perspective on the implications of REACH and food contact material (FCM) regulations for the mechanical recycling of FCM plastics. WASTE MANAGEMENT (NEW YORK, N.Y.) 2021; 119:315-329. [PMID: 33125940 DOI: 10.1016/j.wasman.2020.10.012] [Citation(s) in RCA: 11] [Impact Index Per Article: 3.7] [Reference Citation Analysis] [Abstract] [Key Words] [MESH Headings] [Track Full Text] [Subscribe] [Scholar Register] [Received: 05/11/2020] [Revised: 10/02/2020] [Accepted: 10/08/2020] [Indexed: 06/11/2023]
Abstract
This manuscript provides an overview of the legislative requirements for the use of mechanical recycled plastics in articles placed on the EU market, as seen from the perspective of a plastics recycler. The first part reviews the main principles included in the overarching legislation on Registration, Evaluation, Authorisation and Restrictions of Chemicals (REACH) and to what extent these are applicable for mechanical recyclers of plastics. The interactions between REACH and the Waste Framework Directive (WFD) is discussed, as well as the difficulties for recyclers to comply with certain REACH requirements. In a second part, the focus is moved to the use of recycled plastics as Food Contact Material (FCM). The scope of the different applicable EU FCM regulations is inventorised as well as the key legislative principles involved. A final section is dedicated to the discussion on the authorisation of recycling processes under the FCM regulation and the practical challenges involved for the effective introduction of FCMs containing recycled plastics. Altogether it could be concluded that the complexity of the different legal perspectives, a lack of communication and transparency within the plastic value chain together with technical challenges related to recycling processes have been hindering the effective uptake of recycled plastic FCM (with the exception for bottle PET). The development of targeted solutions across the entire value-chain, taking into account different perspectives in terms of legislation and health protection, economic growth and technical innovations, will be crucial in achieving a circular economy for plastics, including recycled plastics for FCM.
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Affiliation(s)
- Ellen De Tandt
- CAPTURE - Centre for Polymer and Material Technologies, Faculty of Engineering & Architecture, Ghent University, Technologiepark 130, 9000 Ghent, Belgium
| | - Cody Demuytere
- CAPTURE - Centre for Polymer and Material Technologies, Faculty of Engineering & Architecture, Ghent University, Technologiepark 130, 9000 Ghent, Belgium
| | | | - Hiram Moerman
- Apeiron-Team NV, Berten Pilstraat, 4, 2640 Mortsel, Belgium
| | - Nicolas Mys
- CAPTURE - Centre for Polymer and Material Technologies, Faculty of Engineering & Architecture, Ghent University, Technologiepark 130, 9000 Ghent, Belgium; CAPTURE - Laboratory for Circular Process Engineering, Faculty of Bioscience Engineering, Ghent University - Campus Kortrijk, Graaf Karel de Goedelaan 5, 8500 Kortrijk, Belgium
| | - Gianni Vyncke
- CAPTURE - Centre for Polymer and Material Technologies, Faculty of Engineering & Architecture, Ghent University, Technologiepark 130, 9000 Ghent, Belgium
| | - Laurens Delva
- CAPTURE - Centre for Polymer and Material Technologies, Faculty of Engineering & Architecture, Ghent University, Technologiepark 130, 9000 Ghent, Belgium
| | - An Vermeulen
- Pack4Food NPO, Coupure Links 653, 9000 Ghent, Belgium
| | - Peter Ragaert
- CAPTURE - Department of Food Technology, Safety & Health, Faculty of Bioscience Engineering, Ghent University, Campus Coupure, Coupure Links 653, 9000 Ghent, Belgium; Pack4Food NPO, Coupure Links 653, 9000 Ghent, Belgium
| | - Steven De Meester
- CAPTURE - Laboratory for Circular Process Engineering, Faculty of Bioscience Engineering, Ghent University - Campus Kortrijk, Graaf Karel de Goedelaan 5, 8500 Kortrijk, Belgium
| | - Kim Ragaert
- CAPTURE - Centre for Polymer and Material Technologies, Faculty of Engineering & Architecture, Ghent University, Technologiepark 130, 9000 Ghent, Belgium.
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Abstract
The current Dutch recycling value chain for plastic packaging waste (PPW) has not reached its full circularity potential, as is apparent from two Circular Performance Indicators (CPIs): net packaging recycling rate and average polymer purity of the recycled plastics. The performance of the recycling value chain can be optimised at four stages: packaging design, collection, sorting, and recycling. This study explores the maximally achievable performance of a circular PPW recycling value chain, in case all stakeholders would implement the required radical improvement measures in a concerted action. The effects of the measures were modelled with material flow analysis. For such a utopic scenario, a net plastic packaging recycling rate of 72% can be attained and the produced recycled plastics will have an average polymeric purity of 97%. This is substantially more than the net packaging recycling rate of 37% for 2017 and will exceed the EU target of 50% for 2025. In such an ideal circular value chain more recycled plastics are produced for more demanding applications, such as food packaging, compared to the current recycling value chain. However, all stakeholders would need to implement drastic and coordinated changes, signifying unprecedented investments, to achieve this optimal circular PPW recycling value chain.
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