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The European Union is leading the way with regulations designed to improve the environmental footprint of products and trade in general. Two key aspects are reducing the carbon footprint of products to cope with climate change and the overall life cycle of materials through to ultimate end-of-life treatment. This last step is clearly of great importance for recycling companies. As part of the European Green Deal, the European Commission has created a Circular Economy Action Plan that will help strengthen the closed loop of materials recycling in the region.

On the other hand, the United States has turned away from such legislation, the proposal for a Green New Deal having not even been put to the vote. In the meantime, the EU plans to promote and extend its action plan to wider regions.

The European Commission writing“The Circular Economy Action Plan [CEAP] [f]or a cleaner and more competitive Europe stresses that the EU alone cannot achieve the ambition of the European Green Deal for a climate-neutral, resource-efficient and circular economy. The new CEAP thus confirms that the EU will continue to lead the way towards a circular economy at global level and will use its influence, expertise and financial resources to implement the 2030 Agenda for Sustainable Development in Europe. EU and beyond.”

I have previously reported on the EU’s mandatory reporting of substances of very high concern under the Waste Framework Directive (see “What the EU Waste Framework Directive means for product recyclers electronics in the world”). The database of substances contained in products (SCIP) is now fully operational.

Because the SCIP database is open to the public, recyclers anywhere have free access to this information at Only substances listed in the EU REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) Regulation need to be reported. Although serving its purpose and containing millions of entries, SCIP unfortunately does not report other product contents which could include precious and highly recyclable metals such as aluminum, steel, copper , silver or gold. There is also a lack of additional information on the product and its optimal treatment at the end of its life.

Circular economy legislation would help mandate the recycling of all kinds of goods, with a few to be implemented first. And, as we all know, the concept of a circular lifecycle makes perfect sense as opposed to a linear flow of products that largely end up as waste. The concept of circular economy now has a new regulatory face with more specific plans and requirements to breathe new life into recycling. More than ever, the consumption phase would shift to recycling rather than landfilling and/or incineration, closing the circular loop towards resources.

Passports required

Draft Proposal for a regulation on ecodesign for sustainable products would need information about the product that travels with it through its lifecycle until the item is ready for recycling – sort of digital product passport (PPD).

Among other data, the DPP would include the presence of substances of concern and information to guide recycling. This is a complete list as provided in the proposed European Ecodesign Regulation.

“Article 1 Purpose and scope.

“1. This Regulation establishes a framework to improve the environmental sustainability of products and to ensure free movement in the internal market by setting ecodesign requirements which products must meet in order to be placed on the market or put into service. These ecodesign requirements, which will be specified by the Commission in delegated acts, concern:

(a) product durability and reliability;

(b) reuse of the product;

(c) product upgradability, repairability, maintenance and refurbishment;

(d) the presence of substances of concern in the products;

e) energy and resource efficiency of products;

(f) recycled content in products;

(g) refurbishment and recycling of products;

(h) the carbon and environmental footprints of the products;

(i) the expected generation of waste by the products.

“This regulation also establishes a digital product passport (“product passport”), provides for the setting of mandatory criteria for green public procurement and creates a framework to prevent the destruction of unsold consumer products.

“This Regulation applies to any physical good placed on the market or put into service, including components and intermediate products.”

Excluded are foodstuffs and animal feed, live plants and animals and medicines.

Substances of concern, along with recycling guidelines, are key areas where information directly related to a complex product would be made available for access anywhere through digital technology.

How will this be done? Although not entirely certain yet, it seems that some kind of extension to the already familiar computer-readable product codes could be used. One of the general approaches still being defined is how data would be communicated over global computer networks based on some identification on the product itself. One player here is GS1, the standards group that has introduced many types of product barcodes and associated identifiers.

There are many examples of familiar and successful product identifiers. The idea would be that information relevant to the circular economy would be easily retrieved by reading a similar code to be used not only by consumers but also by parties who need to know more about the content and instructions from manufacturers to the recycling.

The new DPP requirements would take effect after 2024, with initial product categories including textiles, construction, industrial and electric vehicle batteries. Another category such as consumer electronics or packaging would also be included.

Batteries are one step ahead

With vehicle electrification and the growth of battery-powered consumer electronics already in full swing, it is no surprise that batteries were selected for early DPP implementation. As you would expect for other product types with some variation, the data that would be made available in a battery DPP would include:

  • source of materials;
  • carbon footprint;
  • recycled materials with percentages used;
  • product durability;
  • guidelines on reuse or remanufacturing, if applicable, and, if not,
  • guidelines on the optimal recycling of materials.

The recycling of rechargeable batteries is of course already well established in EU Member States thanks to Eucobatthe European association of national battery collection systems.

In the United States, collection and recycling assistance has also been available for two decades through Rechargeable Battery Recycling Corp. Call2Recycle.

Although the focus here is on the EU and US, it seems likely that similar coverage will continue to expand to other regions in the years to come. One would expect that the addition of DPP information would somewhat improve but not revolutionize the recycling of existing batteries.

Packaging and plastics

It is less clear at present how the information from the DPP would improve this sector since the current Plastics Industry Society, today Plastics Industry AssociationNos. 1-7 codes have been in place for some time. Adding additional numerical information to polystyrene #6, for example, could hardly make it magically recyclable. The same goes for Miscellaneous. code #7. Even polyethylene terephthalate #1, or PET, which is generally considered recyclable, might derive little benefit from more digital data. Other types of plastic waste regulations and collection targets would be more beneficial to the environment and improve raw materials for specialist recyclers. Indeed, most of these regulations focus on collection goals to avoid sending recyclable plastic, paper and metal packaging to landfills.

Training effects

The development and entry into force of PPDs would have direct impacts on businesses in EU Member States, with ripple effects felt globally. Although detailed regulations are yet to be finalized, the outlook is positive for recyclers who would be able to freely access product content information and recycling guidelines. Where this will make sense for all types of products may become a matter of value yet to be confirmed in practice. One might wonder whether the passport would improve the use of plastic packaging codes already in place. In general, however, the outlook for freely communicating product-related information to effectively track and manage sustainability is positive.

For electrical and electronic equipment, opportunities could arise to improve the ability to better manage substances of concern, but also to gain visibility into precious and recyclable metals that would otherwise be subject to less than optimal generic shredding and dispatch. . foundry scenario.

Much of the success of these passports will depend on the original equipment manufacturers carrying out life cycle assessments and carrying out end-of-life models during the product design phase in order to optimize the dismantling and sorting for circular recovery, then integrating this information into the DPP.

Roger L. Franz works at TE Connectivity, a Swiss company that offers a wide range of connectivity and sensor solutions, proven in the harshest environments, that enable advancements in transportation, industrial applications, medical technology, l energy, data communications and the home. He is based in the Greater Chicago Area and can be reached at [email protected]

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