2 October 2019 by Will Date

Agency’s POPs letter puts WEEE reuse in question

WEEE collectors and processors are digesting the implication of new guidance on the handling of WEEE plastics to minimise the risks posed by persistent organic pollutants (POPs).

It is likely that the guidance will result in a need for greater sorting and separation of what is now deemed potentially hazardous plastic derived from WEEE. It also raises major questions over the future for the reuse of small WEEE items and display units, some in the sector have claimed.

WEEE plastic in storage at a processing facility

The Environment Agency has written to businesses to offer guidance on its position on POPs in WEEE plastics in a communication sent last week. This has been sent to over 1,000 businesses and organisations involved in the management of waste electrical and electronic equipment (WEEE).

POPs thresholds have been under scrutiny due to the recast of the POPs directive in the EU, which sets tougher controls on chemicals historically used as flame retardants as well as other potentially hazardous substances.

The new legislation sets maximum concentration levels for POPs in waste materials to levels are below what have been commonly used in products in the past. If plastic is found to contain levels above the POPs thresholds, it will have to be considered as a hazardous waste.

Persistent Organic Pollutants: An explainer

This means that many items, in particular Small Mixed WEEE, Cathode Ray Tube TVs and Flat Screen TVs, could contain levels of POPs that effectively render them hazardous.

Some plastics from WEEE which would previously have been recycled will now be required to be sent to outlets including high-temperature incineration, for which there is only a limited capacity in the UK.

ICER study

Levels of POPs present in the WEEE stream have been put under the microscope in research from the Industry Council for Electronic Equipment Recycling (ICER) – funded through the WEEE Compliance Fee. This suggested that levels of POPs present in common WEEE plastics are actually higher than previously thought (see letsrecycle.com story).

POPs were among the topics under discussion at the 2019 WEEE Conference, which took place in London last week (25 September). During the Conference, Claire Snow, director of ICER, spoke in detail on the POPs study, including the methodology and findings.

Bromine levels in plastic from cathode ray tube (CRT) display units in excess of those considered acceptable under the POPs directive, were among the areas she highlighted in her presentation.

“CRT plastic is a POPs waste, it has got high levels of bromine, and that could be POPs.”

Claire Snow

“CRT plastic is a POPs waste, it has got high levels of bromine, and that could be POPs. Not all of that will be but you cannot send all CRT backs to a lab to test it to see whether to recycle it or not. 45% of the CRTs in our trial had enough bromine in them that if it were POPs it would take them over the threshold.”

POPs were also found to be present in flat panel displays, small mixed WEEE, and fridge compressors, she told the conference, while further testing is also taking place to determine the potential presence of POPs in cabling.

ICER has estimated that as much as 4,500 tonnes of CRT plastic, 4,300 tonnes of plastic from flat panel display units, and 50,000 tonnes from small mixed WEEE could fall within the POPs threshold.

Currently the only route for the treatment of plastics containing POPs is through high temperature incineration – of which there is very little capacity in the UK – however, Ms Snow revealed that testing is taking place to assess the potential for the material to be used as a fuel in cement kilns.

Environment Agency letter

The Environment Agency’s WEEE lead, Louisa Hatton, spoke earlier in the Conference session, and outlined some of the content of its communication which went out late last week.

The communication offers clearer guidance on the classification and description of waste likely to contain POPs, hazardous waste controls, management of waste-containing POPs and the export of waste as well as reuse of WEEE as EEE, she said.

The letter explains that any hazardous chemicals or POPs present in a consignment of WEEE must be included in the waste description.

The POPs present in the plastics of waste display devices and small mixed WEEE must be destroyed (or irreversibly transformed). You are not allowed to recycle these plastics.

Environment Agency

It goes on to state that POPs present in the plastics from display devices and small mixed WEEE “must be destroyed (or irreversibly transformed). You are not allowed to recycle these plastics.”

“In practice, this means the plastics containing the POPs must be destroyed by incineration (or potentially other high temperature processes like a cement kiln). Bromine separation technologies may be used to separate these POP containing plastics from other plastics and wastes. The latter may then be suitable for recycling.”


However, the picture appears to be more uncertain over the approach being taken with regard to the reuse of WEEE potentially containing POPs.

The guidance states: “if, at any point, an electrical device containing POPs becomes waste, it becomes subject to the legal requirement to destroy (or irreversibly transform) the POP. You are not allowed to reuse this device and it cannot cease to be waste, even if it is in working order. The POPs must be destroyed.

Questions have been raised over what the Agency’s guidance means for WEEE reuse

“This means that waste display devices and Small Mixed WEEE cannot cease to be a waste, or be reused, unless you are sure and can demonstrate that POPs are not present in a particular device or item of equipment.”

One WEEE sector participant remarked that the Agency requirement “could even see the destruction of the reuse market for displays and small items of WEEE.” He concluded that this could be even more difficult in Scotland where all used EEE must be classed as waste on collection unless properly assessed to be otherwise.

Speaking to letsrecycle.com, Craig Anderson, chief executive of the Reuse Network, expressed his concern over what the ruling would mean for WEEE reuse at civic amenity sites and charity shops.

He pointed out that the risk of spreading POPs is ‘encapsulated in the plastic’, and can only be released upon waste treatment. This, he argued, means that reuse of items that may contain POPs would not create any risk of harm as the integrity of the plastic is not compromised during testing and repair.


How will you know or be able to demonstrate if POPs are present?

Posted by Frances Shuttlewood on November 27, 2019

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