On the 23rd December 2019, the Environment Agency published a Regulatory Position Statement 228. This Statement addresses concerns regarding the potential for some waste electrical and electronic equipment (WEEE) plastics to contain persistent organic pollutants (POPs).
The Industry Council for Electronic Equipment Recycling (ICER) researched plastics from different WEEE streams. These include plastics found in liquid crystal displays (LCDs) and cathode ray tubes (CRTs). ICER found that the level of POPs is higher than what is allowed by current regulations.
As a result, those WEEE streams are now deemed hazardous and must be classified with an appropriate European Waste Code. The Regulatory Position Statement 228 provides a limited time frame for currently permitted sites to add those relevant waste codes to their permit. The Statement will be withdrawn on 31st July 2020.
In response to Regulatory Position Statement 228, Wiser Environment is in contact with the Policy Advisor at the Environment Agency. We are seeking clarifications on the following points:
- The Statement does not appear to address how this may apply to those sites who use Waste Exemptions. For example, those operating under an S2 Waste Exemption (storing waste in a secure place).
- There appear to be inconsistencies in the European Waste Codes (EWC). This is because the Environment Agency is suggesting that mixed loads of plastic casings from display equipment must be re-coded as 16 02 15* or 16 02 16.
We will provide an update when we get a response to our clarifications.
As environmental legislation becomes increasingly complex, it is important that industry managers stay well-informed. At Wiser Environment, we have a team of highly-skilled and knowledgeable environmental consultants. If you have any questions or queries about the latest updates to environmental legislation, then contact us or call our team on 01480 462232.