We are heating up
The proponents of POH 21 – 25 / MŽP / decided to reheat instead of recycle.
For many months we tried as the Union of Mixed Plastic Waste Processors, which represents recyclers in Slovakia, mainly material recyclers, to get the proposal POH 21 – 25 / own material/. All our efforts were in vain and, as has been the custom for the past 15 years, this strategic document was also prepared quietly, in the sense of the old well-known saying "when the wind does not blow, the leaves will not move". We would also believe the opposite, that we are wrong, but the subsequent disclosure of the submitted proposal POH 21 – 25 on the MŹP website for the public on 23.12. 2020, with a 21-day opportunity to prepare public comments (during the most important holiday period of the year), confirmed to us that great interest on the part of the presenters in professional debate and consultation with people who mostly spend their whole lives on it is unlikely. After reading the draft POH, our opinion on the matter was only confirmed.
However, here the protagonists of the proposal are very wrong when they naively think that ignorance of the main goals of the strategic documents of the European Union, the European Committee of the Regions, regarding the circular economy, the circular economy, the OH package, the European strategy for OH plastics, the document Modern and successful Slovakia, strategies the environmental policy of the Slovak Republic until 2030, the waste prevention program of the Slovak Republic for the years 2019-2025 and many others will remain unnoticed by us, the "recyclers". And I cannot fail to mention the greatest ignorance, figuratively speaking - the deliberate redrawing of the world-famous pyramid of the waste management hierarchy. I have to admit that the very intelligently prepared prioritization of waste incineration / better said energy recovery / in various parts of the POH proposal over recycling may not be noticed by a less interested person at all.
And in order for this poor support of recycling / material recovery - mechanically, chemically / in POH material to be perfect, our representatives of the POH proposal gave a red light / not to support / chemical recycling. That is, recycling, which is mentioned supportively and positively in all strategic documents of the European Union as one of the few new innovative material recovery options for difficult-to-recycle mixed waste plastics found not only in industry but mainly in municipal waste. What is very funny, however, is precisely chemical recycling / depolymerization /, which in terms of outputs has already had the STN ISO 15270 standard in Slovakia for several years for material recovery and recycling of plastic waste. It is precisely chemical recycling, the outputs of which / already products and not waste / must not be used only for burning as fuel / even if permitted by legislation / but as raw material for the petrochemical industry for the production of new products.
At the same time, we must realize that by not supporting the financing of recycling, which was and has been undersized and unsupported for many years, we will achieve the exact opposite of fulfilling the recycling quotas for plastics. Without the use and support of all forms of recycling, it is impossible to fulfill these recycling goals. Of course, we welcome the new recycling fees, but the fees themselves will only partially cover operating costs, but not the acquisition of innovative recycling technologies. We have dozens of proofs / ÚSZPO / that recycling in Slovakia has been declining in recent years. Since we are interested in you reading this letter, we will now mention only one: in the report of the draft POH it is stated / p. 54,55 /, that in 2018 110 thousand were materially evaluated. tons of plastic waste, which represents 51% / of 215,000 tons / of the total amount of plastic waste generated. Based on our findings / according to Act no. 211/2000 Coll. on free access to information / and after receiving data from all district environmental offices / 73 /, in Slovakia in 2019, less than 79,000 tons of waste originating from plastics were materially evaluated. That is, 36% of the material recovery of plastics less than in 2018. We don't even want to imagine what number 2020 will bring with the annual increasing production of plastics, increasing consumption and the logically increasing amount of plastic waste.
Conclusion:
If we want to fulfill the goals of the recycling rate set by us (the Slovak Republic) according to the agreed % volumes and time horizons, first of all we must comply with the hierarchy of waste management, we must comply with the European strategy for plastics in the circular economy, we must make the entire system of waste management in Slovakia functional and that true waste statistics, clear categorization of groups of not only packaging but also non-packaging products, transparent and fair redistribution of recycling fees through the clearing and settlement center, simplification of legislative processes for obtaining permits for material recovery, co-financing of all types of recycling, not only support for operation through recycling fees, but also the acquisition of innovative technological equipment, supporting the financing of projects focused on research, development and application of technology for recycling, where the state of waste comes to an end and a product is created as the highest form evaluation. Please, let's not confuse the concept of energy recovery with the concept of material recovery in our frivolity and simplification. These two terms are related only in words, but the reality in the case of approval of such a draft POH will mainly have a climatic impact for Slovakia. With an increased share of energy recovery, i.e. combustion, we will never achieve a reduction in greenhouse gases and the carbon footprint. On the contrary, we will contribute significantly to global warming and to the increase of the mentioned indicators. Nevertheless, we have nothing against the energy recovery of such Slovak waste, the recycling of which is technically or economically inexpedient. We only point out that the waste that can be recycled should be recycled to the maximum extent possible with the full support of the state without any difference in the types of recycling in accordance with the European strategy for plastics in the circular economy.
By supporting the energy recovery of waste without adequate support for recycling and limiting the import of waste-derived fuels, we will seal Slovakia's position as the incinerator of the European Union.
Note:
- A) European strategy for plastics in the circular economy, ( page 14, point 4.3 ) – The effect of innovative solutions for advanced sorting, chemical recycling and better design of polymers can be great.
- B) New EU action plan for the circular economy For a cleaner and more competitive Europe (page 18, point 6.3) - Support for the transition through research, innovation and digitization. European companies are leaders in circular innovation. The European Regional Development Fund, through Smart Specialization, LIFE and Horizon Europe programs, will complement private financing of innovation and support the entire cycle of innovation to bring solutions to market. Horizon Europe will support the creation of indicators and data, new materials and products, substitution and elimination of hazardous substances based on a "safe by design" approach, circular business models and new production and recycling technologies, including exploring the potential of chemical recycling, taking into account the role of digital tools in achieving the goals of the circular economy.
- C) Modern and successful Slovakia, National Integrated Reform Plan (page 6, 35) - Reducing greenhouse gas emissions, increasing energy efficiency and the share of renewable resources, transitioning to a circular economy and sustainable transport are key priorities in the green economy. Slovakia has a large investment debt, especially in the completion of sewerage and water supply systems, environmental burdens and low energy efficiency of buildings. Green policies are essential for the flexible response of the economy to megatrends such as decarbonization or new technologies. The regulatory reform will create space for increasing the share of renewable energy sources, more flexible and resilient networks. Complex renovation of buildings will contribute to increasing energy efficiency. The reform of waste management will lead to higher recycling. 5. Transition to a circular economy - The municipal waste recycling rate is one of the lowest in the EU, and landfilling is still the dominant form of waste management in Slovakia. In this way, the economy loses a significant volume of materials that could be reused.
- D) Waste prevention program of the Slovak Republic for the years 2019 – 2025 (pages 5, 10, 24) The intention of PPVO was not only to fulfill the obligation imposed by the legislation of the EU and Slovakia, but also to change the principles and direction in waste management. In the Slovak Republic, the main and only emphasis has long been placed on fulfilling the goals of recycling and waste recovery.
As part of continuous efforts aimed at transforming the European economy into a more sustainable system and implementing the ambitious Circular Economy Action Plan, the European Commission adopted a set of measures in 2018, which are:
The European Strategy for Plastics in the Circular Economy and annexes aimed at transforming the way plastic products are designed, manufactured, used and recycled. All plastic packaging should be recyclable by 2030. The strategy also emphasizes the need to introduce specific measures, possibly a legislative instrument, to reduce the impact of single-use plastics on the seas and oceans.
The potential of plastic waste recycling is largely untapped in the EU. The reuse and recycling of end-of-life plastics is very low, especially compared to other materials such as paper, glass or metals. Currently, the demand for recycled plastics in Europe only accounts for approximately 6% of the total demand for plastics. In recent years, the EU plastics recycling industry has been negatively affected by low commodity prices and uncertainty regarding outlets.
It has been estimated that around 400 million tons of CO2 are produced worldwide during the production of plastics and the burning of plastic waste. By increasing the use of recycled plastics, it is possible to reduce the dependence on the extraction of fossil fuels for their production and achieve a decrease in CO2 emissions. It is estimated that the potential annual energy savings that could be achieved if all plastic waste worldwide were recycled is equivalent to 3.5 billion barrels of oil per year.
E) Standard STN ISO 15270 - the standard is intended for material recovery and recycling of plastic waste. This standard is also a guide to the procedure for achieving material recovery.
F) Strategy of the SR environmental policy until 2030 – Greener Slovakia. (chapter 10) - Towards a circular economy, the goal is set: "By 2030, the recycling rate of municipal waste, including its preparation for reuse, will increase to 60%, and by 2035, the rate of landfilling will be reduced to less than 25%.".
H) Expert opinion on the method of thermal depolymerization of plastic material and equipment for its implementation prepared by prof. Ing. Ivan Hudec, PhD (STU - Director of the Institute of Natural Synthetic Polymers) - The obtained mixture of liquid hydrocarbons can be used as a raw material for the petrochemical industry for the production of new products of an organic nature or as a substitute for liquid fuels obtained by oil processing. In this way, fossil resources are saved and at the same time a valuable raw material is obtained from the waste, or an easily storable and usable liquid fuel. The device does not burden the environment with a large amount of exhalates and greenhouse gases and can significantly contribute to the processing of difficult to recycle plastic waste.
I) Opinion of the European Committee of the Regions — Communication on a European strategy for plastics in the circular economy. Better recycling
Development of sorting and recycling technology
Strongly supports research and innovation in the field of new sorting and recycling technologies, including depolymerization. In theory, this could solve many of the current problems with sorting and recycling plastics.
J) CEFIC Opinion / March 2020 / - to meet the ambitious European goals, it is necessary to recycle much more waste plastic. In this context, CEFIC emphasizes the potential of chemical recycling of plastic waste.
K) Report of the European Environmental Agency (EEA), of which the SAŽP is also a member of the consortium from March 2019, where on page 32, point 4.3 Environmental impacts it is written, we quote: In the production of plastics, emissions can be reduced by improving energy efficiency and using renewable energy sources ( to 3.7 tons of CO2 per ton of plastic). In comparison, low mechanical recycling (including cleaning, remelting and upgrading steps) emits 1.4 tonnes of CO2 per tonne of plastic, while chemical recycling (such as pyrolysis, where plastics are broken down into monomers or chemicals) can be used as raw materials for new products) the calculated CO2 emission is 1.0 tons of CO2 per ton of plastic. Assuming that a potential 56 percent of plastic volume could be mechanically recycled or reused, and another 11 percent could be recycled through chemical recycling techniques (such as pyrolysis and depolymerization), this would roughly reduce emissions from 233 to 144 million tons of CO2 per year. compared to the production of new plastics and their incineration at the end of their useful lives. (Material economy, 2018).
USZPO
