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The European Union is at the forefront with regulations to improve the environmental footprint of products and commerce in general. Two key aspects are reducing the carbon footprint of products to combat climate change and the full lifecycle of materials through to final end-of-life treatment. This last step is obviously of great importance for recycling companies. As part of the European Green Deal, the European Commission has drawn up a Circular Economy Action Plan that will help enforce closed-loop material recycling in the region.

In contrast, the US has veered away from such legislation, with the Green New Deal proposal not even being put to a vote. In the meantime, the EU plans to promote its action plan and expand it to larger regions.

The European Commission writes“That Circular Economy Action Plan [CEAP] [f]or a cleaner and more competitive Europe stresses that the EU alone cannot meet the EU’s ambitious goals European Green Deal for a climate-neutral, resource-efficient and circular economy. The new CEAP thus confirms that the EU will continue to lead the way towards a circular economy at the global level and will use its influence, expertise and financial resources to implement the 2030 Agenda for Sustainable Development in the EU and beyond.”

I previously reported on the EU’s obligation to notify Substances of Very High Concern under the Waste Framework Directive (see “What the EU Waste Framework Directive means for electronics recyclers around the world”). The Substances Contained in Products (SCIP) database is now fully functional.

Because the SCIP database is publicly available, recyclers anywhere have free access to this information at Only substances that are listed under the REACH regulation (Registration, Evaluation, Authorization and Restriction of Chemicals) of the EU have to be reported. Unfortunately, while the SCIP serves its intended purpose and contains millions of entries, it does not report the other ingredients of products that may contain valuable and highly recyclable metals such as aluminium, steel, copper, silver or gold. There is also a lack of additional information about the product and its optimal disposal at the end of its life.

Circular economy legislation would help enforce the recycling of all types of goods, with a select few to be implemented first. And as we all know, the concept of a circular life cycle makes perfect sense as opposed to a linear flow of product that mostly ends up as waste. The circular economy concept now has a new regulatory face with more specific plans and requirements to breathe new life into recycling. More than ever, the consumption phase would be turned over to recycling instead of landfill and/or incineration, closing the loop back to resources.

passports required

The design Proposal for an ecodesign regulation for sustainable products would need information about the product accompanying it throughout its life cycle until the item is ready for recycling – sort of digital product pass (DPP).

Among other data, the DPP would include the presence of substances of concern and information to guide recycling. This is a complete list as foreseen in the proposed EU Ecodesign Regulation.

“Article 1 Subject and Scope.

“1. This regulation creates a framework to improve the environmental performance of products and ensure the free movement of goods in the internal market by setting ecodesign requirements that products must meet in order to be placed on the market or put into service. These ecodesign requirements, which are further elaborated by the Commission in delegated acts, relate to:

(a) product durability and reliability;

(b) reusability of the product;

(c) upgradeability, repairability, maintenance and refurbishment of Products;

(d) the presence of substances of concern in products;

(e) product energy and resource efficiency;

(f) recycled content in products;

(g) remanufacturing and recycling of products;

(h) CO2 and environmental footprint of the products;

(i) expected generation of waste materials from products.

“This regulation also introduces a digital product passport (“product passport”), establishes binding criteria for green public procurement and provides a framework to prevent unsold consumer products from being destroyed.

“This regulation applies to all physical goods that are placed on the market or put into service, including components and intermediate products.”

Excluded are food and feed, living plants and animals and medicinal products.

Substances of concern and recycling policies are key areas where information directly related to a complex product would be made widely accessible through digital technology.

How is that done? Although not entirely certain, it appears that some sort of extension of already known computer-readable product codes could be used. One of the general approaches, yet to be defined, is how the data will be communicated across global computer networks based on an identification on the product itself. One of the players here is GS1, the standards group that has implemented numerous types of product barcodes and associated identifiers.

There are many examples of well-known and successful product labels. The idea would be that information relevant to the circular economy can be easily retrieved by reading a similar code, which can be used not only by consumers but also by parties who know more about the content and the manufacturer’s instructions for recycling have to.

The new DPP requirements would come into effect sometime after 2024, with initial product categories including textiles, construction, industrial and electric vehicle batteries. Another category such as consumer electronics or packaging would also be included.

Batteries have a head start

With vehicle electrification and the growth of battery-powered consumer electronics already in full swing, it is not surprising that batteries were chosen for the early implementation of the DPP. As would be expected with other product types with some variation, the data that would be made available in a battery DPP would include:

  • source of materials;
  • carbon footprint;
  • percentage of recycled materials;
  • shelf life of the product;
  • Reuse or refurbishment policies, if applicable, and if not,
  • Guidelines for optimal material recycling.

The recycling of batteries has of course long been established in the EU member states Eucobatethe European association of national collection systems for batteries.

Collection and recycling support has also been available in the US for two decades through Rechargeable Battery Recycling Corp. available Call2Recycle.

Although the focus here is on the EU and US, it seems likely that similar coverage will be extended to other regions in the coming years. It is to be expected that the addition of DPP information could improve existing battery recycling somewhat, but not revolutionize it.

packaging and plastics

It is less clear at this point how DPP information would improve this sector given the plastics industry society now in existence Association of the Plastics IndustryNo. 1-7 codes has been around for quite some time. Adding additional digital information to polystyrene #6, for example, couldn’t wait for it to magically become recyclable. The same applies to other things. Code #7. Even #1 polyethylene terephthalate, or PET, which is widely considered recyclable, could do little with more digital data. Other types of regulations on plastic waste and collection targets would have greater environmental benefits and improve raw materials for specialty recyclers. In fact, most of these regulations focus on collection targets to avoid sending recyclable plastic, paper and metal packaging to landfill.

ripple effects

The development and entry into force of DPPs would have a direct impact on companies in EU Member States, with knock-on effects felt around the world. While the detailed regulations are not yet finalized, the outlook for recyclers who can freely access information about product ingredients and recycling policies is bright. Where this makes sense for all types of products may be a matter of value, yet to be confirmed in practice. One might wonder if the passport would improve the use of already existing codes for plastic packaging. In general, however, the prospects for freely communicating information related to products in order to effectively track and manage sustainability are positive.

For electrical and electronic equipment, there could be opportunities to improve the ability to better manage substances of concern, but also to reveal valuable and recyclable metals that would otherwise fall under a less than optimal, generic shred-and-send-to-smelter scenario.

Much of the success of these passes will depend on OEMs performing life cycle assessments and end-of-life models during the product design phase to optimize disassembly and sorting for recycling, and then incorporating this information into the DPP.

Roger L. Franz is with TE Connectivity, a Swiss company that offers a wide range of connectivity and sensor solutions proven in the harshest environments, enabling advancements in transportation, industrial applications, medical technology, energy, datacom and home. He is based in the greater Chicago area and can be contacted at [email protected]


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