What is Green List waste?A regulator’s perspective

Allison TownleySenior Scientific Officer,Northern Ireland Environment Agency

What is Green List waste?

Policy priorities What the law says Green List is Green List from co-mingled

collections Regulatory approach

Getting to compliant waste exports

The right type of waste At the right quality To the right country For the right type of ESM recovery In compliance with the applicable

control system

What is Green List waste?

The legal answer:

Annex III to WSR– List of wastes subject to the general

information requirements laid down in article 18

Origin?– OECD decision Appendix 3 – “GX123” codes– Annex IX Basel Convention – “B1234” codes

What isn’t Green List waste? Any waste that isn’t listed in the Green List Any waste listed in any other Annex to the WSR

– Y46 waste collected from households - unless appropriately classified under a single entry in Annex III

Mixtures of waste – even if all Green List components “Contaminated” Annex III waste

If it isn’t Green List export it is either: Prohibited, or Subject to notification controls

Mixtures of Green List waste

WSR – does not follow OECD

Notification unless listed in WSR Annex IIIA Annex IIIA – currently empty Annex IIIA to non-OECD? Notification

pending further “write round” and revised Green List regulation

Contaminated with other material to the extent: Increases the risks associated with the wastes

sufficiently to render them appropriate for submission to the procedure of prior written notification and consent, when taking into account the hazardous characteristics listed in Annex III to Directive 91/689/EEC

Or

Prevents the recovery of the wastes in an environmentally sound manner

Material outputs from MRFs destined for exportCo-mingled household waste input must be:

“properly sorted”

And therefore is not: Y46 waste collected from households - unless

appropriately classified under a single entry in Annex III, or

A mixture of wastes; or Excessively contaminated

Key Annex III entriesB3010 - Solid plastic waste:The following: Plastic or mixed plastic materials, provided

they are not mixed with other wastes and are prepared to a specification.

B3020 - Paper, paperboard and paper product wastes

The following materials, provided they are not mixed

with hazardous wastes: Waste and scrap of paper or paperboard.

Key Annex III entries

B2020 - Glass waste in non-dispersibleform: Cullet and other waste and scrap of

glass except for glass from cathode-ray tubes and other activated glasses

Green list waste exports from Northern Ireland in 2008(Total weight 414484 Tonnes/4641 Annex VII's)

Plastic, 16028, 4%

Paper, 83587, 20%

Other (WEEE, UCO, Tyres),

4771, 1%

Metals, 310098, 75%

Destination of green list waste exports from Northern Ireland in 2008 as % weight

Spain35%

Portugal28%

China7%

France11%

Other2%

Norw ay2%

Hong Kong5%

Indonesia7%

Netherlands3%

Properly sorted?

The regulatory challenge

Rapidly increasing trade 5000 exports per annum Port inspections Must get it right at the MRF Upstream regulation is key

MRF audits

12+ MRF audited Approx 2/3 good or OK Approx 1/3 cause for concern

– Marginal or poor quality output– Poor record keeping– Don’t know where output goes

MRF as quality material manufacturerCan operators demonstrate:

Outputs are consistent? They know what the contaminants are? The waste has been “properly sorted”? A documented audit trail to demonstrate

consistent outputs of known parameters? Where the material goes and how it’s used?

If we don’t get it right?

No public confidence No end user confidence Miss recycling recovery diversion targets Infraction Additional legislation

More information?

http://www.ni-environment.gov.uk/waste/regulation-and-legislation/

transfrontier_shipment_of_waste.htm