1. Plastic-Recycling - "The Success Story of the Incineration"

It is impossible to imagine our daily live without plastics and the number of applications steadily increases, but at the same time plastic waste already jeopardizes our environment and the Oceans with alarming proportions.
In the EU waste directives aim at avoiding waste and support re-use and recycling, but for plastic waste the incineration with energy recovery becomes increasingly the method of choice, when 2/3 of the European plastic demand is concentrated on only 5 member states (Germany, Italy, France, UK and Spain)9).
2016 The Way of PlasticPlastic producers regularly report on increasing recycling rates, but only half of the plastic consumed is collected again as waste and thereof only 1/3 is recycled. There exists only one EU Directive with a very low recycling quota for plastics and Germany equated the incineration with recycling via a so-called “heating value clause” until 2017.
New directions like REACH and RoHs will improve the protection of consumers and environment but may also have the potential to stimulate recycling SMEs to send even larger volumes to incineration plants.
Valuable waste streams (e.g. WEEE) already became attractive for illegal business models and more than 2/3 is already lost.
Recycling rates of public authorities are often distorted and multiple counting causes higher recycling and/or recovery quotas.
Without new plastic recycling technologies, recycling will be limited to “pure” plastic waste collection streams (e.g. PET bottles, EPS packaging) and the rest will end up as heating fuel in incinerators.

The Art of Statistics
2014 APME Plasti RecyclingWe replace steel, glass, wood and other materials with more and more plastics. Yet whilst society’s consumption of plastics steadily increases, and our landfills reach their limits, for years we still maintain the public impression that, through waste collection and recycling, we can manage our resources. The EU Commission demonstrates resoluteness by imposing high collection and recovery quotas, which do not necessarily lead to more recycling.
However, the reality only becomes evident when looking at existing published data until 2014 from another point of view: We still bury 31% and incinerate 40% of the collected plastic waste (in 2003 it was 60% and 20%). At this rate we are still returning 76% (18,1 million tons) of plastic waste to the environment.
The plastic demand in the EU has doubled from 24,6 MM tons in 1993 to 47,5 MM tons in 2005 and stagnates on this level until today when the recycling quota declined from 66% in 1993 to 46% in 2006 and stagnates at 54%.
The data for the charts have been taken from a study published in 2015 entitled „Plastics - The  Facts for 20149)“ and from earlier studies1-8) from Plastics Europe – Association of Plastics Manufacturers.
Plastic producers favor the incineration as energy recovery because these volumes are removed from the circulation and will not place existing production capacities at risk by too high recycling volumes, when on the other side high recycling rates are the proof for a functioning circular economy.
In line with the motto „Believe only in the statistics you have manipulated yourself“10) the high recycling rates as published by APME were strongly questioned by the European Plastics Recyclers Association (EuPR) in 2006 and with anger it was pointed out that APME would add the incinerated volumes to the recycling rate. On top of this the figures do not distinguish between collection, export and recycling11).
EuPR requested that the EU Commission, the European Parliament and the Member States should initiate the plastic waste/recycling directive that had been blocked for several years by the strong lobby of the petro-chemical companies.

In the EU Plastic Waste is only an Alternative to Fossil Fuel

In the EU plastic waste is not considered as resource but as indispensable fuel for reaching own objectives and our waste directives reflect this very distinctly. For example the Packaging Waste12), Waste Electrical and Electronic Equipment (WEEE)13) or End-of-Life Vehicles (ELV)14)-Directives have identical objectives: “Prevention of waste, the reuse, recycling and other forms of recovery” and incineration (for energy recovery) is explicitly explained as excluded from recycling.
In the update of Directive 94/62/EG on Packaging Waste dated 11.02.2014 it is concluded „The incineration of waste at plants with energy recovery is regarded as contribution to the realization of the objectives“.
2011 WEEE plastic content per categoryFor waste electrical and electronic equipment (WEEE) and end-of-life vehicles the Definition (Article 2 or 3) of “recovery” as: any of the applicable operations provided for in Annex IIB to Directive 75/442/EEC15) opens the door to incineration, because the first one on the list is “R1 Use principally as a fuel or other means to generate energy”. Plastic recycling for WEEE can be avoided because the recycling quotas for the different equipment categories are usually lower than the metal content39)(see graph).

2014 APME Incin. Landf. Recycl. trendThe packaging waste directive is the only one with a specific plastic recycling quota:”minimum 22,5% by weight for plastics, counting exclusively material that is recycled back into plastics”, what can be considered as an exit clause. This target is obviously significantly lower than for glass, paper and board (60%) and metals (50%) and was not adapted until now.
So it should not be a surprise that annual total volumes of land-filled and incinerated plastic waste stagnates on the same level according to APME statistics, when the incinerated volume increases and the land-filled one declines.
This is not going to change, because when recycling plastic waste in future, the fractions containing brominated flame retardants (WEEE, ELV) have to be separated, but because no recycling techniques are used which are able to separate such dangerous substances, there remains only the oven. And then we have not looked at flame-retarded plastic waste from the construction sector (e.g. insulation boards with expanded polystyrene).

The National Legislature as Pyromaniac violating EU Law

The „Analysis of Regulatory Barriers along the Recycling-Chain for Plastic Waste“ of the German Öko-Institut (Institute for Applied Ecology) from March 2014 – prepared on behalf of the German  Federal Environmental Ministry – explains the intended preference for the incineration very clear and comprehensible16).
In 2012 99% of the total plastic waste was recovered, but thereof only 43% were recycled and 56% were incinerated. The average recycling rate of all EU member states is 28%.
In the national implementation of Art. 4 No 2 of the Waste Frame Directive17) from 1st June 2012, Germany as „European Champion of Plastic Recycling“ provides measures in §8 section 3 of the German Closed Substance Cycle and Waste Management Act (KrWG - Kreislaufwirtschaftsgesetz)18), that equal status of incineration (energy recovery) and recycling has to be assumed, if the heating value of a single waste stream, without mixture with other substances, accounts for at least 11.000 KJ/kg, that is for plastics always the case as a general rule. With this regulation the recycling priority was generally and without detailed justification cancelled. This is considered as a national implementation against EU law19).
With this so-called „Heating Value Clause“ waste owners got a decision right on the recovery method and enables them to incinerate plastic waste streams instead of recycling them. Although the legislator is authorized to issue legal requirements in order to recycle plastic waste in a greater extent than previously instead of incinerating it, he does not make use of it.

It lasted 5 years until the "heating value clause" was revoked again on 1st June 2017.   

REACH, RoHS and POP als Fire Accelerators for Plastic Waste?

Consumer and industrial wastes of plastic products are subject to the waste legislation. However during plastic recycling processes the waste characteristic ends again and depending on the technique it has to be clarified, which REACH31) registration requirements have to be complied with, based upon whether the recycled material is considered as substance, mixture or product under REACH36). Therefore a plastic granulate as mixture would potentially need to be REACH registered when it is no longer considered as waste. A molded part made from such granulates would be considered as product and would not need to be registered. According to REACH Article 7 substances/mixtures in products only need to be registered, if they contain more than 0,1 weight% SVHC (substances of very high concern). Because no European-wide standardized criteria exist for the ending of the waste status, this needs to be nationally clarified for the respective recycling step.
With the introduction of the „Recycling Privilege”37) under REACH Art. 2 7d) incentives were created for the recycling of substances in the EU and exempt from registration when the following criteria are fulfilled:

  1. The recycling company resides and produces in the EU.
  2. The recycled substance is identical with a substance, that is already registered.
  3. The recycling company has the required information for the preparation of a safety datasheet.

Plastics consist of polymers (which monomers have to be registered) and in addition often additives, in order to achieve certain properties (e.g. flame retardants, softeners, stabilizers etc.). Therefore a recycler in the EU needs to know exactly, which monomers and “additive”-substances are present in his recycled plastics and whether substances are included which are to be classified as SVHC.
2016 REACH fire accelThe recycler is responsible for the correctness of the safety datasheets and in case of wrong and insufficient information, it could result in liability claims against him. This will lead to additional analytical costs for the proof of the substance identities for the purpose of the classification and labeling (GHS classification) and it will be more difficult for a recycling company than for a primary producer of plastics and can therefore be seen as a barrier16).
The RoHS Directive (Restriction of Hazardous Substances) 2011/65/EU29) aims at the restriction of the use of certain hazardous substances in electronical and electronic equipment and in plastics for example polybrominated biphenyls (PBB) and diphenylethers (PBDE) as flame retardants are in the scope.
Today WEEE waste contains hazardous chemicals, which are no longer allowed to be used and need to be removed before a plastic can be re-used.
The Stockholm Convention is a global treaty that aims to eliminate or restricts the production, use and release of „Persistent Organic Pollutants“, POPs) and the EU regulation 850/200432) is the legal precondition for a ratification. The so-called POP List33) contains among others polychlorinated biphenyls (PCB) und hexabromocyclododecane (HBCDD), which have been used as flame retardants.
Until 2015 insulation materials made of polystyrene were equipped with HBCDD (EPS with 0,7%, XPS with 1,5%) and installed. In future recycling will only be possible, if the legal threshold value of Annex I of the POPs Regulation34), effective 22 March 2016, of 100 mg/kg will not be exceeded. This counts for packagings, plastic housings or textiles which contain HBCDD. Effective 11 March 2016 there exist a direct link between German and European waste regulations and all waste containing POPs35), which exceed the threshold limits in Annex IV are considered as dangerous and accountable30).
Without new techniques like the CreaSolv® Process that allows to remove hazardous impurities from contaminated plastic waste (WEEE, ELV, construction), which have to be collected separately, mechanical recyclers are pushed to their limits and they will only be able to have such dangerous waste incinerated in a verified way.  

Interpol and the WEEE-Waste in the EU

2015.08 CWIT Report WEEE FlowIn Europe every year 9,5 million tons of electro(nic) equipment end up in the trash. Under the lead of Interpol 5 organization and 2 UN institutions have found in a time-consuming 2 year study20), that only 35% (3.3 MM tons) of the old appliances end up at the municipal collection points. The remaining 65% (6.15 MM tons) are

•    non-compliantly processed (3.15 MM tons)
•    scavenged and parts stolen (0.75 MM tons)
•    thrown into the waste bin (0.75 MM tons)
•    exported (1.5 MM tons).

Interestingly more than 4.65 MM tons is wrongfully mismanaged or illegally traded within Europe itself and it is estimated that the loss of raw materials causes an annual loss of revenue between € 800 million and €1.7 billion for the member states.
The illegal trade with WEEE waste in the EU is of course highly profitable, with low risk to be discovered and the penalties are too low to be dissuasive.   

Recycling-Lie and “Figures being Rubbish”

The German Federal Environment Agency classified beverage cartons as “ecologically advantageous” and exempted them from the obligation to charge a deposit, because it is possible to recycle the single components from paper/plastic/aluminum composite packaging and beverage carton manufacturers like market-leader Tetrapak advertised with “complete recycling”.
Based on evidence provided by Deutsche Umwelthilfe (DUH – German Environmental Relief) the lobby association of beverage carton manufacturers „Fachverband Kartonverpackungen für flüssige Nahrungsmittel e. V.“ (FKN) admitted in April 201521), that for years they misled consumers about the recycling of beverage cartons, because research showed that recycling of pure aluminum from beverage cartons was not practiced in industrial scale in Germany22). Since then Tetrapak changed the advertisement to „100% recyclable“ and in addition FKN  informed that plastic foil remnants from German beverage cartons will be exported to Xiamen in China since beginning of 2015.
But also state statistics are misleading, because they count what is delivered into a recycling plant. Dirt and moisture adds to the weight and counted but not deducted. This is the case for packaging waste, as for any other waste stream23). Waste often passes many different stations, as for example a yoghurt cup via a sorting plant comes to a recycler and from there to a waste treatment plant in order to finally end up in an incineration plant. Each time the cup is counted for the statistics until it leaves the “waste regime”24). The investigation has shown that everything is counted for the recycling quota that enters a sorting installation, but it is not counted what finally will really be recycled.
If a recycling plant is operated by a public authority the whole incoming waste is considered as „recycled“. This assumption may be correct for glass and paper which are collected separately, but it is not correct for the collection of packaging waste (“yellow bags” in Germany), because even recyclers move thousands of tons to incineration plants. The recycling quota is therefore knowingly distorted more than once. In order to reduce cost plastic waste sorting companies apply improper storage. This causes declining quality and yields of usable material and the remains are only good enough to be incinerated according to the German „Recycler“ Association BVSE (Bundesverband Sekundärrohstoffe und Entsorgung e.V.)38). Additional there exists destructive competition among waste incineration companies that offers a cheap alternative for the sorters.
In any case it can be assumed, it is assured that the plastic foil remnants from beverage cartons for China are counted for the German recycling quota and will not be lost.
The residues from exhaust gas cleaning of waste incineration plants will be used as “rock filling” (cavity filling in old mines) or in road construction, whereby this is of course again a “countable” recovery operation25).
2014 Plastic End usesAccording to APME statistics we only collect half of the plastics consumed in the EU (54% in 2014) and APME explains this with the many long-lasting products5). This is doubtful, because the statistics already cover a period of 20 years and the consumption in average stagnates over the last decade. There exist of course long-lasting products like EPS insulation foams in construction, but packaging, electronic equipment and even cars have a shorter life-time. According to the end-uses of plastics there should be much more in our collected waste. 2014 Plastic waste outstandingA new study for the German Federal Environment Agency28) determined that corporations actually do plan the lifetime of their products. Preferences of consumers and the technological advances do change faster and so products will be replaced faster.
Our today recovery quotas – as measured by waste – are therefore only „half the truth“, because if totaling all un-collected plastic volumes during the production period from 1993 until 2014, there are still 528 million tons in circulation, or may be located at places not known to us.

Conclusion: We collect approximately only half of the consumed plastics as waste and still incinerate and land-fill 2/3 of it - and probably much more!


No Bright Future for Plastic Recycling in the EU

If the prognoses of the German Federal Environment Agency will come true, the waste generated will shrink in the coming years and the competition for waste will intensify, because treatment of plastic is expensive and will become more complex (REACH), but as fuel it will be very suitable as fuel based on its heating value. 2016 The Way of PlasticBased on the pressure of operators of waste incineration plants to be sufficiently loaded, plastic recycling will have worse chances than before26). According to the Federal Association of the German Waste Disposal Industry (BDE - Bundesverband der Deutschen Entsorgungswirtschaft) every fourth of 71 incineration plants could be closed throughout Germany.  The overcapacity will become a problem for the recycling: Collection and sorting of 1 ton waste is already twice as expensive than the incineration. The German Federal Environment Agency already confirmed upon request in 2014, that half of all collected packaging waste is incinerated27).
Because Germany is leading in the field of plastic recycling, it cannot be better in other member states.
With generously specified quotas and intelligent recovery targets the EU will carry on reporting increasing recycling quotas.
Without new recycling processes like the CreaSolv® Process, which are able to separate plastic composite materials and/or remove toxic pollutants from plastic waste (ELV, WEEE and construction) this will be technically impossible, because our materials will become more complex and not simpler.
REACH and RoHS are important for product safety, consumer and environment protection, but require an appropriate competency in application and implementation during recycling.
Normal mechanical recycler working with mixed plastic waste streams, will very likely face problems.
The member states are responsible for national implementation of directives and so it also depends on their motivation, how far they want to go with the application and control and to what extent they really wish to recycle plastics.

We wait to be surprised!


  1. APME 2008 – Compelling facts about plastics for 2006
  2. APME 2008 – Compelling facts about plastics for 2007
  3. APME 2009 – Compelling facts about plastics for 2008
  4. APME 2010 – The Facts – plastic production and recovery 2009
  5. APME 2011 – The Facts – plastic production and recovery 2010
  6. APME 2012 – The Facts – plastic production and recovery 2011
  7. APME 2013 – The Facts – plastic production and recovery 2012
  8. APME 2014/2015 – The Facts – plastic production and recovery 2013
  9. APME 2015 – The Facts – plastic production and recovery 2014 – Link
  10. Statistisches Landesamt Baden-Württemberg 2011: Ich glaube nur der Statistik …” Link pdf
  11. Plasticker News 21 April 2006 „EuPR: Concern about Plastics Europe Study on Waste Management“ – last check on 03.08.2016 - Link
  12. Directive 94/62/EC on packaging and packaging waste
  13. Directive 2002/96/EC on waste electrical and electronic equipment (WEEE)
  14. Directive 2000/53/EC on end-of life vehicles (ELV)
  15. Council Directive 75/442/EEC on waste – Annex II B
  16. Öko-Institut e.V. März 2014 Kurzanalyse Nr. 9: Analyse rechtlicher Hemmnisse entlang der Recyclingkette bei Kunststoffabfällen - Link
  17. Directive 2008/98/EC of the European Parliament and oft he Council of 19 November 2008 on waste and repealing certain Directives
  18. Gesetz zur Förderung der Kreislaufwirtschaft und Sicherung der umweltverträglichen Bewirtschaftung von Abfällen vom 24. Februar 2012, BGBl. I
  19. Gemeinsames Schreiben der Umweltverbände DNR, NABU, BUND, DUH und bfub an die EU-Kommission vom 27.4.2012, Link 
  20. Countering WEEE Illegal Trade (CWIT) Summary Report, Market Assessment, Legal Analysis, Crime Analysis and Recommendations Roadmap, August 30, 2015, Lyon, France – Link pdf 12MB
  21. Unterlassungserklärung des Fachverbandes Kartonverpackungen für flüssige Nahrungsmittel e. V.“ (FKN) am 30. April 2015 über sortenreines Recycling von Aluminium aus Getränkekarton-Abfällen. - Link
  22. Pressemitteilung der Deutschen Umwelthilfe zur Recyclinglüge von Getränkekartonhersteller vom 20.05.2015 – last check 03.08.2016 - Link
  23. Wirtschaftwoche 27. Mai 2015 – Michael Billig „Streit um Verpackungen eskaliert“, – last check 03.08.2016 - Link  
  24. Wirtschaftswoche 8. November 2014 – Michael Billig „ Abfall-Statistik – Recherche im Zahlenmüll“, last check 26.07.2016 – Link 
  25. Bayrisches Landesamt für Umwelt – Sonstige Verwertung: Verwertung im Bergversatz – Homepage last check 26.07.2016 – Link 
  26. Süddeutsche Zeitung 10.09.2014 „Wettkampf um den Müll“ Homepage last check 26.07.2016 – Link 
  27. WAZ – Westdeutsche Allgemeine Zeitung vom 10.04.2014: Die Hälfte des Recycling-Mülls wird verbrannt“, last check 03.08.2016 – Link
  28. Umweltbundesamt Texte 11/2016 „Einfluß der Nutzungsdauer von Produkten auf ihre Umweltwirkung: Schaffung einer Informationsgrundlage und Entwicklung von Strategien gegen „Obsoleszenz“ – Link pdf 8MB 
  29. Directive 2011/65/EU vom 8. Juni 2011 on the restriction oft he use of certain hazardous substances in electrical and electronic equipment.
  30. EnBauSa vom 16.02.2016 „Abfallverordnung macht alte EPS-Dämmung zu Sondermüll“, last check 04.08.2016 – Link  
  31. Umwelt-Bundesamt – REACH Verordnung last check 03.08.2016 – Link 
  32. Regulation (EC) No 850/2004 on persistent organic pollutants and ammending Directive 79/117/EWG
  33. Stockholm Convention – Listing of POPs, last check 03.08.2016 – Link 
  34. Commission Regulation (EU) 2016/293 of 1 March 2016 amending Regulation (EC) No 850/2004 on persistent organic pollutants as regards Annex I (HBCDD)
  35. Verordnung über das Europäische Abfallverzeichnis (AVV), geändert am 4. März 2016
  36. Regulation 1907/2006/EC concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) from 18 December 2006.
  37. Federal Ministry of the Environment 08/2012 REACH and the recycling of plastic from March 2012, last check 04.08.2016 – Link  
  38. Frankfurter Rundschau vom 13.03.2013 „Recycling – Verbrennen ist billiger“ – Link
  39. Dr. A. Mäurer & Dr. M. Schlummer „Kunststoffrückgewinnung aus Elektroaltgeräten, bag Workshop 12. Mai 2011 - Link