PVC Industry comments on the three Horizontal Initiative studies released by the European Commission on 13th. April 2000
The European PVC Industry, represented by ECVM 1, ECPI 2, ESPA 3 and EuPC 4, welcomes publication of the three PVC studies that form part of the European Commission Horizontal Initiative.
These studies are wide ranging. As a result, the PVC industry is currently undertaking a thorough examination and expert analysis of the studies in order to provide comments to the European Commission within two weeks.
Regardless of what material is investigated, any in-depth review or Horizontal Initiative is likely to raise questions that will need to be answered.
The PVC Industry is confident in its product, which has been used for more than 40 years and is one of the most well researched modern materials. PVC applications have never been demonstrated to cause any harm to human health or the environment. Nevertheless, the industry is committed to continuous improvement and further developing the understanding of its product. In particular, it is working to improve resource efficiency, minimise emissions during production and develop integrated waste management solutions.
The industry will continue working to ensure that PVC remains a material of choice and will co-operate fully with the European Commission as it develops its policy on PVC.
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In the areas covered by these studies, the following general comments can be made:
- Mechanical recycling is application, rather than material, specific. There are practical criteria that need to be met, such as cost-effective sorting and collection, before viable mechanical recycling schemes can be established. The effectiveness of waste collection, which should also be application rather than material specific, is critical as this is a major element of the total recycling cost (approximately 60 per cent).
- 2. Any long-term projection of waste quantities is subject to uncertainty, especially when looking as far ahead as 20 years. Within any forecasts, it is essential to distinguish between theoretical waste quantities and what is actually available for collection. This is particularly important for a material such as PVC, where many applications have long lifetimes (some up to 100 years) and where some applications are not readily available for collection (e.g. soil buried pipes and cables).
- Mechanical recycling is already a reality for many PVC applications. Capacities will increase as collection schemes are extended to generate higher volumes of good quality sorted recyclable waste. A mechanical recycling rate of 18 per cent for PVC applications in 2020 quoted by the Prognos study is a significant rate that compares favourably with alternative materials.
- Flue gas cleaning equipment is essential for all Municipal Solid Waste Incinerators (MSWI), independent of whether PVC waste is present or not. This equipment treats not only hydrogen chloride (HCl) but also acid gases arising from the combustion of wastes other than PVC. Consequently there is no fixed cost contribution for this equipment specific to PVC1.
- The contribution to the total waste stream of heavy metals from PVC is insignificant, with the exception of cadmium1. The use of cadmium, however, is declining in PVC products as it is substituted for other stabilisers.
- Residue quantities generated from flue gas cleaning are dependent on the type of technology used1. When properly allocated, PVC only affects the variable costs of the total MSWI operation by 1-2%.
- All waste materials disposed of via MSWI have their own specific cost contribution or impact. For PVC this impact, like for wood, is placed between those for mixed plastic waste and typical household waste1.
- 5. The environmental impact of contaminant leaching from salt residues needs to be balanced against the positive role which chlorine plays in capturing otherwise volatile heavy metals.
- Temperatures within European landfills range between 18ºC and 55ºC, with an average of 35ºC. Accelerated biodegradation of PVC in laboratory simulations at temperatures above 55ºC is therefore not representative of the real landfill biodegradation process. Testing at temperatures as high as 75ºC excludes typical biodegradation effects and induces heat ageing, which is a very different degradation process.
- An independent study2 into the long-term behaviour of PVC products under landfill conditions was published in June 1999 by waste management experts at leading universities in Germany and Sweden. This study investigated the degradation cycle of a typical landfill, using laboratory simulation and analysis of leachate samples taken from landfill sites across Europe.
- The overall conclusion of the June 1999 independent study was that landfill is an acceptable disposal option for PVC products and does not constitute a significant risk to the environment.
- PVC and municipal solid waste combustion: burden or benefit? produced by the TNO Institute of Environmental Sciences, Energy Research and Process Innovation, Netherlands. TNO Report R 99/462. December 1999.
- Long-term behaviour of PVC products under soil-buried and landfill conditions, produced by the Technical University of Hamburg-Harburg, Germany, and Linköping University, Sweden. 2nd. revised edition. July 1999.
Represents the European PVC producing companies and is a division of the Association of Plastics Manufacturers in Europe (APME). Its membership includes the 10 leading European PVC producers which together account for over 95 per cent of Europe's production of PVC resin.
Ave E van Nieuwenhuyse 4B-1160 Brussels
Tel: + 32 2 676 74 41
Fax: + 32 2 676 74 47
ECPI represents the interests of 26 member companies that are involved in the production of plasticisers. Plasticisers are esters (mainly phthalates) which are used generally in the production of flexible plastic products, predominantly PVC.
Ave E van Nieuwenhuyse 4
Tel: + 32 2 676 72 60
Fax: + 32 2 676 73 01
ESPA represents the whole of the European stabilisers industry through its five branches:
- European Cadmium Stabilisers Association (ECADSA)
- European Lead Stabilisers Association (ELSA)
- European Tin Stabilisers Association (ETINSA)
- European Mixed Metal Solid Stabilisers Association (EMMSSA)
European Liquid Stabilisers Association (ELISA)
Ave E van Nieuwenhuyse 4
Tel: + 32 2 676 72 86
Fax + 31 2 676 73 01
EuPC represents approximately 30,000, predominantly medium-sized, plastic processing operations in Europe. These companies have over one million people on their payrolls, 85% of whom work for companies that employ less than 100 people. The individual members combine to produce a processing capacity of more than 30 million tonnes of plastic every year.
Avenue de Cortenbergh 66
Tel: + 32 2 732 41 24
Fax: + 32 2 732 42 18