Flanders as a Guiding Country: Renewi sees Belgium daring to take the lead in plastic recycling

To sell recycled materials as a product, companies in the Netherlands need an "end-of-waste status," while in Flanders, they need a "raw material declaration." They must be able to demonstrate through self-assessment that their waste can be safely processed into products. In the Netherlands, recycling companies often get lost in a maze of bureaucracy to obtain such a status. Regional environmental services and the Human Environment and Transport Inspectorate (ILT) take a long time to assess applications.

Sticking Their Neck Out

In Flanders, there is a single point of contact for a raw material declaration: the OVAM (Public Waste Agency of Flanders). "The OVAM sticks its neck out and makes a decision. It’s a yes or no. In the Netherlands, the authorities sometimes stall the decision or leave it uncertain," says Patrick Deprez, Product Sales Director at Renewi. According to his colleague Peter Vingerhoeds, industrial waste specialist at Renewi, this is the biggest difference between the Netherlands and Flanders. "For example, two years ago, when we asked the ILT for end-of-waste status, they said it was not their responsibility. When we then transported the material to Belgium, OVAM asked ILT if this was waste, and they quickly became involved," he explains.

In Playmobil

Renewi, an international waste processing and recycling specialist, is active in both the Netherlands and Belgium. In Belgium, the company sells few materials under the end-of-waste status regime. In the Netherlands, however, it does. From two locations, it supplies recycled material for new plastic: Coolrec in Waalwijk, where plastic from refrigerators processed at facilities in Dordrecht and Liège is refined, and Renewi Acht near Eindhoven, where a sorting facility for hard plastics was opened in March. This recycled material is used in various new plastic products, from flower pots to Playmobil toys.

For certain products from the Waalwijk line, the company has obtained end-of-waste status, approved by the local environmental service and ILT. This allows the recycled material to be used in production processes without needing a "waste permit," both in the Netherlands and abroad.

Determining What Is Waste

For plastics from the sorting facility in Acht, Renewi, supported by Royal Haskoning DHV, conducted research to demonstrate that it is no longer waste. This research has been submitted to the relevant authorities, who still need to formulate a formal position. In the meantime, Renewi is already selling its plastic as raw material. Legislation states that the holder of the material decides whether something is waste or not. "You can trade in recycled material until someone else says it is not," says Vingerhoeds. In practice, many customers prefer more certainty about the material's status. "The consequences of mistakes can be very large and negative," he explains.

Establishing Certainty

Deprez also finds such clarity on status very important. "We want to avoid rashly declassifying something and saying it will never be waste or is waste. If something is waste, a duty of care arises. Chain responsibility is reasonably well described in both the Netherlands and Flanders," he explains.

Companies selling recycled material need strong legal grounds to solidify end-of-waste status. Otherwise, they can be held liable by customers, such as producers of new plastic products.

Flanders as a Guide Country

Renewi also supplies plastic waste from refrigerators to Belgian RAFF Plastics. At that point, it is not yet recycled material with end-of-waste status but still waste. Therefore, Renewi does not need to apply for a raw material declaration in Flanders. RAFF Plastics must apply for it themselves with OVAM. Renewi observes that OVAM is relatively flexible with companies, especially when it is clear where the plastic comes from and what it is intended for. This is the case, for example, when a company makes flower pots from recycled material. "In that sense, Flanders is indeed a guide country, as such applications can be relatively easily submitted to OVAM, which gives a quick response," says Deprez.

Clear Guidelines

On the other hand, OVAM is strict when asked to allow recycled material to be used freely, for example, in the food or toy industry. OVAM has written clear guidelines for companies, enabling them to assess whether something can obtain end-of-waste status. "This is described accurately in a kind of best-practice guide," says Deprez. The Netherlands also has such a guide. "Only the interpretation varies by environmental service. They are working on a more streamlined approach, but that hasn’t been easy so far," says Vingerhoeds.

National Raw Material Declaration

Deprez and Vingerhoeds support the call for a single point of contact. "This is indeed an urgent bottleneck. The decentralization to environmental services has been a painful mistake. This authority could be better placed at the national level. It could also be arranged that such a national raw material declaration could then be quickly and adequately submitted to the EU or individual member states, which would accept or reject it, so that recyclers know where they stand," they suggest.

Need for EU Regulation

The EU already applies more or less uniform criteria for end-of-waste status through the Waste Framework Directive. According to the two, these criteria are clear. "A European-level elaboration, like the Flemish or Dutch guidelines, would be welcome. And an EU regulation, as exists for glass and metal, would be even better. This is already being developed for plastics, but it should be given priority," they say.

The principle that everything should be a raw material unless it is deemed waste makes sense, they argue. But in practice, things still go wrong, and waste is used irresponsibly. "Securing this through recognized channels and licensed facilities provides more legal certainty for both the disposer and the receiving parties," they conclude.

About This Series

The Dutch platform Groene Chemie Nieuwe Economie (GCNE) aims for circular chemistry with innovative technologies, without fossil fuels and raw materials and zero CO2 emissions by 2050. Recycling plastics plays an important role in this goal. Too often, however, recycled material is still classified as waste. In the Netherlands, recycling companies must report to one or more of the 28 environmental services to obtain end-of-waste status. The ILT also conducts inspections. In Flanders, there is only one point of contact, OVAM, which issues a "raw material declaration."

According to GCNE, a paradigm shift is needed: assume that everything is a raw material unless a self-assessment decision tree shows that it should be considered waste. For this self-assessment, a uniform EU-wide approach based on international ISO standards is necessary. Each country should then have a single point of contact for raw material declarations.

This series is published by Change Inc., edited by André Oerlemans.

The first article can be read via this link.