Roadblocks for the Circular Economy of WEEE Plastics: A Call for Informed Classification Practices

6 min readNov 26, 2019


Gergana Dimitrova, Researcher and Project Manager Fraunhofer Institute for for Reliability and Microintegration IZM

Anton Berwald, Researcher and Project Manager Fraunhofer Institute for for Reliability and Microintegration IZM

Prof. Margaret Bates, Professor of Sustainable Wastes Management University of Northampton — UK

Roberta Bernasconi , EMEA Sustainability Sr Manager Whirlpool EMEA — Italy

Dr. Ruediger Kuehr, Director UNU-SCYCLE — Germany

Prof. Kim Ragaert, Ghent University-CAPTURE, Belgium

Chris Slijkhuis, Commercial General Manager of MGG Polymers — Austria

Classifying WEEE plastics as “hazardous waste” risks making EU recycling of WEEE plastics impossible.

Most of the WEEE plastics are high value tech plastics and technology exists in the EU to produce REACH and RoHS compliant Post-Consumer Recycled plastics and ensure safe plastic recycling. A small proportion of these WEEE plastics is compounded with flame retardant substances. Only a limited number of these Flame Retardants are restricted as Persistent Organic Pollutants (POPs). Plastics containing brominated flame retardants can be separated to be discarded, thus destructing and eliminating these POP BFRs. WEEE plastics recycling plants generally do not have permits to take in hazardous wastes and a classification of WEEE plastics in some regions in Europe is hampering the recycling of WEEE plastics.

The amount of WEEE plastics within the European Union alone is estimated to be in the order of 1.5 Mio MTs and these consist of mainly engineering plastics which have been produced from fossil resources and the impact of large quantities of energy for the refining, polymerisation, extrusion and compounding of these plastics. Post-Consumer Recycled plastics from these engineering plastics from mechanical recycling processes leave all this invested energy intact within the polymer matrix and the recycling of these engineering plastics therefore represents a major environmental benefit. EMPA has made full LCA Analyses of the comparison of WEEE recycling with the production of virgin plastics and the comparison of WEEE recycling with the incineration of these WEEE plastics (Annex 1).

The recycling of End-of-Life Electronics follow a process, that is described clearly in the European TAC guidance document Annex II and article 6.1 of 2002/96:

“Substances, preparations and components may be removed manually, mechanically or chemically, metallurgically with the result that hazardous substances, preparations, and components and those mentioned in Annex II are contained as an identifiable stream or identifiable part of a stream at the end of the treatment process. A substance, preparation or component is identifiable if it can be (is) monitored to prove environmentally safe treatment.”

The entire recycling industry of End-of-Life Electronics has developed following this guidance. Most of the WEEE volumes in the EU follow a process in which the WEEE is de-polluted and subsequently shredded. In line with this TAC guideline, the shredder residues from WEEE are treated to recover a plastics mix from these residues and this plastics mix is treated by specialized plastic recycling plants. The “target plastics” without substances of concern can be recycled into Post-Consumer Recycled plastics with characteristics that allow these secondary raw materials to be re-used in new electronic appliances or other durable products. In line with the above definition the compliant recycling industry monitors the identifiable stream of plastics containing restricted substances such as the POP BFRs to prove environmentally safe treatment.

Much of the information about how WEEE plastics recycling is happening is already covered in the Poly-CE paper with the title: “Illegal and Sub-Standard Plastic Waste Treatment: When Recycled Plastics May Be Harmful for Consumers — and Why Black Plastics Are Unjustly Blamed

By far the majority of the WEEE plastics does not contain Brominated Flame Retardants (BFRs) and of the approximately 5–10 % that do contain BFRs, only approximately 30 % consists of POP BFRs. Deca-BDE and the group of the PBDE’s have been used intensively in electronics in the past and the EU recycling industry has to deal with this legacy of PBDE’s.

The innovative plastics recycling industry in collaboration with the Horizon 2020 financed project PolyCE have developed systematic sorting and separation concepts in order to produce RoHS and REACH compliant Post-Consumer-Recycled plastics from these complex mixes of plastics from WEEE (Waste of Electric and Electronic Equipment). The separated plastics containing the restricted POP BFRs are eliminated in appropriate incineration processes, in line with the relevant Basel Convention guideline documents.

The technical method how to measure the content of Brominated Flame Retardants is based upon the analysis standard IEC EN 62321–3–1. This standard is validated for 1000 ppm of Bromine as element and there is no other viable test method available to date. As long as this test method is not available for any validated lower values, the WEEE plastics community has called for keeping the maximum low POP content at 1000 ppm for Deca-BDE or for the group of PBDEs. And this has finally been decided in the latest recast of the EU POP Regulation. The consequence of this decision is not that suddenly WEEE plastics above the Low-POP-Treshold become classified as hazardous waste. Merely it implies that such wastes need to be monitored to make sure that these are treated in facilities that separate the plastics with the POP BFRs and that these separated plastics are discarded properly (i.e. incinerated for destruction of the POP substances) and this has been the case ever since some BFRs substances have been restricted, which is well over 15 years.

A recent question raised by an NGO referred to the classification of WEEE plastics as hazardous wastes in several parts of Europe. The inquiry claimed that the PolyCE work would seem to fundamentally go against recent moves by at least parts of the EU to ban the use of plastic from WEEE which may contain POP substances. Recent developments in the UK, in France and in Germany indeed show that any WEEE plastics from mixed WEEE or displays are (potentially) classified as hazardous waste. As we know of no WEEE plastics recycling facility that is permitted to take in hazardous wastes, these decisions risk to stop WEEE plastics recycling altogether. In reality these plastics thus risk to be traded before leaving Europe through ports that have virtually no controls on BFRs specifically.

By classifying WEEE plastics as hazardous, all of these valuable plastics from WEEE would need to be discarded, as there are no facilities in Europe that we know of capable of taking them in as raw material for secondary raw material. Incineration capacities would need to be increased for this type high calorific waste and as a result all plastics for EEE products would need to be made from virgin materials. This would make it impossible to match the recycling and recovery targets set for WEEE in Europe, it would be in complete contradiction with the objectives of the development of a circular economy and it would result in an immensely increased energy consumption and much higher CO2 emissions as a consequence of the requirement to use virgin plastics only.

About PolyCE:

PolyCE (or Post-Consumer High-tech Recycled Polymers for a Circular Economy) is a European Commission funded Horizon 2020 project that brings together a consortium of 20 expert organisations to take on the challenge of e-waste plastics, promoting a circular economy, and building a future-oriented knowledge transfer base. Read more about the project and it’s objectives, results and latest news here:




@EU_H2020 Project enabling #recycling of #plastics from #electronicwaste for a more #sustainable future. #InvestEUresearch #ChooseRecycled