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March 2019


BREXIT – where companies need to take action
EEE Producer Symposium in Pretoria, South Africa on 7 February 2019
Battery Producer Symposium in Pretoria, South Africa on 8 February 2019
Landbell Group meets producers in Poland

Interview with Anna Gajowniczek, Teamleader, Global Regulatory Tracking
Changes to Swedish Packaging Law in 2019
UK government opens several consultations on packaging

European Commission working on packaging essential requirements and guidance on modulated fees
European Commission to implement new rules for the calculation of recycling targets

ECHA proposes to restrict intentionally added microplastics
Provisional agreement on POP Regulation

Disposal sector sees room for improvement in digitization

PACE and WEF present a new circular vision for electronics
Circularity Gap Report 2019
Second EuPC survey on the use of recycled plastic materials

Revolutionary insulation material on the road to success


BREXIT – where companies need to take action 

As the UK withdrawal date approaches this month, companies are beginning to take action in the following areas: 

UK-REACH Compliance:
The UK Department for the Environment, Food and Rural Affairs (Defra) has released more detailed guidance on how companies importing or manufacturing in the UK can comply with the new UK-REACH regulation. The guidance presents example scenarios and specifies the timelines that would apply in each case. It also clarifies that the new UK-REACH system will treat Product and Process Orientated Research and Development (PPORD) dossiers and intermediates in the same way as they currently are under REACH. Defra has also confirmed that they will not charge submission fees for UK-based registrations that are grandfathered into the new UK-REACH system. 

EU-REACH Compliance:
UK-based manufacturers and formulators may engage the services of an EU-27/EEA based Only Representative (OR) before the withdrawal date, i.e. contracts and letters of appointment may be put in place. However, this appointment has no legal basis until after withdrawal. To formally appoint an EU-27/EEA OR, the UK based companies must transfer their registrations to the newly appointed EU-27/EEA OR using the online REACH-IT system. The European Chemicals Agency (ECHA) will open a ‘Brexit window’ in REACH-IT to enable UK-based manufacturers and formulators to transfer their registrations to their appointed OR thereby ensuring REACH compliance for their EU-27/EEA based customers. This window will be open from 12-29 March (23:00 UK time). If an EU-27/EEA OR is not appointed during that time, the EU-27/EEA customers (importers) will have to submit their own registrations.
Authorised Representatives and WEEE:
Several EU Member States allow producers based in another EU country to take over the producer obligations of their distributors, but they do not allow this for producers established in a country outside the EU. For example, in the case of a company that is based in the UK and sells EEE to distributors in Italy, under Italian legislation, the distributors are classified as the responsible producer and have to register themselves and join a producer compliance scheme. However, to simplify things for its distributors, the producer may decide to keep these obligations. The producer can do this, if it is based in the EU, by appointing an authorised representative in Italy. This will no longer be possible for UK companies once the UK leaves the EU.

Please contact us:
  • If you need support with your UK-REACH or REACH registrations
  • If you need the services of a UK or an EU-27/EEA based Only Representative
  • If you are concerned about your Authorised Representative arrangements for WEEE
Contact Landbell Group here

EEE Producer Symposium in Pretoria, South Africa on 7 February 2019  

Landbell Group company, European Recycling Platform (ERP) hosted a symposium for the Electrical and Electronic Equipment (EEE) industry in South Africa on 7 February 2019. More than 50 participants, including recyclers, public authorities and other stakeholders, took part.  

The morning session included a general introduction to the environmental regulation which required the EEE and packaging industries to submit a Waste Management Plan (WMP) – the permit application for operating producer responsibility organisations (PROs) – by 6 September 2018. All PROs for WEEE and lighting have now submitted their WMPs and Thalo Mogomola, from the South African Department of Environmental Affairs (DEA), gave an update on the application process. ERP shared its experience of operating 35 PROs/WMPs and explained how it has supported other industry associations around the world. 

During the afternoon session, ERP gave participants the opportunity to discuss the latest developments in South Africa and to formulate a strategy for producers. Some of the most important discussions focused on how the industry can influence the WMP process so that it is practically implementable for EEE producers; how to manage the expected high levy on specific products, e.g. refrigerators and other heavy goods; and how to combat free riders in the system.

For more information, please contact us

Battery Producer Symposium in Pretoria, South Africa on 8 February 2019  

ERP also hosted a symposium to update the portable and lead acid battery industry on the latest developments in extended producer responsibility (EPR) legislation in South Africa. The South African Department of Environmental Affairs (DEA) will extend EPR regulations to cover batteries and pesticides in 2019. 

Two waste management acts, issued in 2013 and 2016, lay the foundation for the EPR regulation for batteries. One act banned the landfilling of batteries by 23 August 2021 and the other calls on producers to develop a Waste Management Plan (WMP) to implement the phasing-out of batteries to landfill. Since the industry has not yet developed a WMP for batteries, the DEA intends to impose a mandatory WMP in 2019. One specific presentation addressed the requirements for a WMP and the necessary process flow for a mandatory WMP, including a stakeholder consultation process.  

During the symposium, the portable and lead acid battery producers discussed the possibilities of setting up a voluntary WMP, how to prepare for a mandatory WMP, and how ERP can support the process.

For more information, please contact us

Landbell Group explains German Packaging Act to producers in Poland 

On 12 February 2019, Landbell Group met a large number of producers at the Ministry of Entrepreneurship and Technology in Warsaw, Poland.  

In cooperation with the German-Polish Chamber of Commerce and the Polish Ministry of Entrepreneurship and Technology, Cecile Gainche, Mikolaj Jozefowicz, and Wojtek Swietochowski from Landbell Group were invited to introduce the new German Packaging Act to producers. The key point was to explain to Polish companies exporting to Germany how to comply with the new obligations.  

After their presentation, the Landbell Group team answered questions from the attendees and received numerous requests for further help regarding the German Packaging Act. 

“This event was a perfect occasion for us to introduce Landbell Group and to present our international expertise to a large audience,“ commented Wojtek Swietochowski, Head of Global Sales at Landbell Group. 

“This was also a great opportunity for us to explain the new regulations to companies in Poland, to make sure they understand the new requirements and to expand our Polish network,” explained Mikolaj Jozefowicz, Head of ERP Poland.

For more information, please contact us

Interview with Anna Gajowniczek, Teamleader, Global Regulatory Tracking 

What’s your job at Landbell Group? 
I’m in charge of the Global Regulatory Tracking Team, which researches Extended Producer Responsibility (EPR) legislation around the world. We provide support to Landbell Group’s consulting team which, in turn, helps customers comply with their global EPR obligations. On top of that, we recently created new services for our clients to keep them up-to-date with the latest EPR regulatory requirements. We have produced a range of AT A GLANCE and IN DEPTH reports, as well as Legal Registers to keep our clients informed.  

What are your most important tasks and challenges?  
When I started working for Landbell Group, my main task was to create a space where regulatory information could be stored in a structured, user-friendly and up-to-date way. Then my responsibilities expanded to content generation itself. Regulatory tracking requires robust information channels which are managed by my team and our network. Because the number of countries which we are looking into is also expanding, my team has become more and more international since language skills and cultural knowledge are so important to what we do. Therefore, our team speaks not just English and German, but also German with Austrian dialect, Russian, Ukrainian, Arabic, French, Polish, and soon also Spanish and Greek. The core team is also complemented by the skills of our international partners. 

How did you come to work for Landbell Group? 
For many years, I worked as an Environmental Specialist for Sony, one of the founders of European Recycling Platform. My main role was to ensure that the company was in compliance with environmental legislation. I also created EPR reporting tools for multiple countries. I was very happy when Landbell Group gave me the opportunity to draw on my previous experience to support a variety of international clients from different sectors.  

What do you do for the environment in your private life? 
I try to do what I can. I carefully sort my waste and recycling. I grow my own vegetables in the garden. I switch off lights when they’re not being used and I try to spend more time outside walking rather than watching TV or browsing the Internet!  

Changes to Swedish Packaging Law in 2019 

The new year brought new changes to Sweden’s packaging law, with a particular emphasis on extended producer responsibility (EPR). The new law, which comes into full force in 2021, replaces the ordinance from 2014 and places a heightened level of responsibility on producers: the new law requires producers of packaging to register, pay annual fees, and report to the Swedish Environmental Protection Agency.

Producer compliance schemes are also affected by the changes. From 2021, schemes for household packaging will need to register with the Environmental Protection Agency and obtain a permit, although schemes for business packaging will be exempt from this obligation. Going forward, schemes will also be responsible for informing households and businesses about how to sort their packaging correctly, available collection solutions, and the different possibilities available for recycling packaging materials.

EPR obligations affecting newspapers, magazines, directories and producers of other paper products will also come into effect in 2021. 

For more information, please contact us

UK government opens several consultations on packaging 

The United Kingdom government has released four consultations on:
  • Reforming extended producer responsibility for packaging producers
  • Consistency in household and business recycling
  • Introducing a deposit return scheme for drink containers
  • Plastic packaging tax
The first three consultations cover flagship policy commitments introduced in the recently published Resources and Waste Strategy and propose options on how to reach the goals outlined in the strategy. The proposed plastic packaging tax, which is set to come into effect in April 2022, will heavily increase the cost of producing and importing plastic packaging that uses less than 30% recycled content. The consultation on the new tax will give all parties concerned insight into how this instrument will work, while also giving them the opportunity to suggest design options on how to best implement it. 

The consultations will run for 12 weeks, ending 13 May 2019.

More information on the DEFRA website

European Commission working on packaging essential requirements and guidance on modulated fees 

The European Commission has begun work on a new study to evaluate the essential requirements for packaging on the European market with independent consulting firm, Eunomia. The study, “Effectiveness of the Essential Requirements for packaging and packaging waste and proposals for reinforcement”, will look at essential requirements, improving enforcement of said requirements, and how to eliminate overlaps with the criteria for modulated fees. According to the Commission the study could lead to the adoption of an implementing act to harmonize requirements. 

In parallel, the Commission and Eunomia are also working on a second study, "Preparation of the Commission’s Guidance for Extended Producer Responsibility (EPR) Schemes", which will – among other things – give recommendations on how to best implement modulated fees. 

Eunomia will run two stakeholder workshops on 11 and 12 March in Brussels to discuss both studies in detail. The first workshop will focus on packaging and feed into both studies, the second one will focus on WEEE and batteries and mainly feed into the study on EPR schemes.

Landbell Group has registered to take part in both workshops.

European Commission to implement new rules for the calculation of recycling targets 

The European Commission is working on detailed rules for the calculation, verification and reporting of data with regard to the recycling targets set in the Waste Framework Directive (WFD). The goal of the new rules is to provide methods which are both ambitious and comparable between Member States. 

The Commission intends to define clear and harmonised calculation rules to avoid mixing the recycling rates of targeted materials with those of non-targeted materials. The weight of waste used for the calculation of the recycling rate will now be determined after the sorting process, i.e. before the recycling process, in order to achieve comparable recycling rates across Member States.  

The implementing measure, which establishes rules for the calculation, verification and reporting of data, in order to confirm compliance with the targets set in the WFD, is due to be finalised by the end of March. It needs to be approved by Member States before entering into force. 

ECHA proposes to restrict intentionally added microplastics 

The European Chemicals Agency (ECHA) has submitted a proposal to restrict the use of intentionally added microplastics in mixtures used by consumers or professionals. The restriction aims to reduce the amount of microplastics released into the environment in the European Union (EU) by 400,000 tonnes over the next two decades. 

Microplastics find their way into the environment, where they can persist for thousands of years. Once in the environment, they can be easily ingested and make their way into the food chain. As of yet, the effects of these microplastics on human health is not well understood. 

There are currently no restrictions on the use of microplastics at an EU level, although several Member States have already introduced bans on microplastics in certain products, namely wash-off cosmetic products.

Provisional agreement on POP Regulation 

Negotiators from the European Parliament and the Romanian Presidency have reached a provisional agreement to toughen the rules on persistent organic pollutants (POPs), a list of chemicals deemed by the United Nations to be especially dangerous to human health and the environment.  

The new regulation maintains tough restrictions for POPs, while adding several new substances, including the brominated flame retardant decabromodiphenyl ether (decaBDE), which is now limited to trace amounts of 10 mg/kg when present in substances.  

When present in mixtures and articles, the unintentional trace contaminant value is set at 500 mg/kg for the sum of all bromodiphenyl ethers (BDEs). Recycling associations and companies like Landbell Group’s European Recycling Platform have warned that too low concentration levels for decaBDE put the recycling of plastics from electronic waste at risk. Current measurement standards for recycling processes are validated to measure down to limits of 1000 mg/kg of total brome and are not suitable to monitor the proposed limits. The lower concentration levels would also require recycled materials to be mixed with higher amounts of virgin materials.

The initial proposal by the European Commission was adopted in March 2018, and was followed by discussions within the European Parliament, and then by trialogue negotiations which started in December 2018. The agreement will be submitted to EU ambassadors for endorsement on behalf of the Council, following technical finalisation of the text. Parliament and Council will then be called on to adopt the proposed regulation at first reading.

Disposal sector sees room for improvement in digitization 

A new global survey of waste disposal providers has uncovered valuable new information on digitization in the industry, as well as insight into attitudes. The results from the study were used to compile a digital transformation barometer, giving an in-depth look at current progress in the industry and helping identify where more work is needed.

The research led to three key findings:
  • Digital transformation requires leadership in change management
  • The digital part of the digital transformation is the most challenging
  • Legacy systems are the biggest challenge to successful digital transformation
Companies were asked to rate themselves on a scale of 1-10 in five areas of digital transformation. The average scores were as follows:
  • leadership and culture: 6.9
  • value chain: 6.5
  • employee engagement: 6.3
  • business intelligence: 5.9
  • new technologies: 5.7
An overall average of 6.3 suggests an industry-wide need to increase focus on these drivers and prioritize continued digital transformation in waste management.

Please contact us for more information on Landbell Group’s digital solutions
Download the full study here

PACE and WEF present a new circular vision for electronics 

The Platform for Accelerating the Circular Economy (PACE) and the World Economic Forum (WEF) have published a joint study calling for a global reboot in the way electronic goods are managed throughout their lifecycle. The report supports the United Nations’ (UN) e-waste coalition, a group of 7 UN entities aiming to work together to better support all parties in addressing the challenges associated with e-waste. The study brings to light several new developments regarding the e-waste problem that we are currently facing.  

One of the most jarring figures highlighted is the amount of e-waste generated annually: 44.7 million tonnes, the equivalent of 125,000 jumbo jets. The report presents new solutions for better tackling this growing problem and highlights the economic opportunities. It also calls for a reboot of the global electronics system, and a more circular approach to using and reusing components. The current annual e-waste stream is worth $62.5 billion, which should provide a powerful economic incentive for those producing, using and disposing of electronic goods to buy into this new circular vision.

Download the full report here

Circularity Gap Report 2019 

The social enterprise, Circle Economy, has released its Circularity Gap Report 2019, which highlights that a mere 9% of materials in the global economy are currently re-used annually. The report makes several recommendations, including extending product lifetimes, increasing recycling, using waste as a resource, and improving circular design.

Governments are also called upon to take a number of measures, including:
  • abolishing financial incentives that encourage overuse of natural resources
  • raising taxes on emissions and excessive resource extraction
  • lowering taxes on labour, knowledge and innovation in the key areas mentioned above
Circle Economy’s report stated that nearly half of all materials put into the economy are used in the construction and maintenance of houses, roads, offices and infrastructure. This points to a massive potential to cut down on consumption through more circular processes, and a rethinking of supply chains. With global material use tripling since 1970, and set to double once again by 2050, a rethinking of how materials are used and reused is vital to the future of our economy and the environment.

Download the full report here

Second EuPC survey on the use of recycled plastic materials 

The European Plastic Converters Association has released its second study on the use of recycled plastic materials (rPM). Building on the results of the first study, the second study consisted of 376 companies from 21 countries filling out an online questionnaire with the aim of providing more detailed information on the reasons why plastic converting companies are not using more rPM. 

Some of the key takeaways include:
  • 76% of plastics converters believe that improving the collection and sorting of plastic waste is the best way to increase the quality of rPM
  • 80% of those surveyed stated they have already implemented measures to improve the quality of recyclates
  • Current conditions are not beneficial to an increase in rPM; respondents said that only 2 of the 10 plastic materials included in the survey had sufficient supply to ramp up use
In addition to the survey, EuPC has pledged to organize 50 workshops for converters and recyclers throughout Europe by 2020 to improve the quality of rPM and increase its use. A third survey is set to follow in 2019, as well as an online tool to monitor the use of rPM in the European plastics converting industry.

Revolutionary insulation material on the road to success 

With the Green Alley Award, Landbell Group showcases the best innovations in the circular economy, often long before they hit the mass market. Last year’s winner, the British startup Aeropowder, and its innovation Pluumo, is a good case in point. Aimed at the growing sector of online grocery shopping and “recipe box” companies, Aeropowder offers a thermally insulated packaging solution that is truly sustainable. 

The growing demand for sustainable solutions is echoed in CEO Ryan Robinson’s assessment of the past year: “When we started selling Pluumo in mid-2018, it was a crucial moment for us. It showed that we had developed Pluumo from a concept to the fully functional product for which customers are willing to pay! In fact, momentum is building, not only with consumers and the general public, but also in politics, which is helping to promote sustainable packaging solutions.” 

In the coming year, the start-up would like to focus on optimizing all of its product related processes. Currently, the team is working to fully automate the production process and to develop an end-of-life solution for Pluumo. “Of course we want to minimize the environmental impact of our product throughout the product life cycle,” confirms Robinson. “Our main focus in the coming months, however, will be on the completion of the automated production run for Pluumo. We hope to be able to supply our customers with more reliable Pluumo units in the future. This will allow us to win even larger companies as customers or partners.”

More information on the Green Alley Award Blog
11 – 12 March 2019, 9th World Convention on Waste Recycling and Reuse, Singapore

13 March 2019, EuRIC's Annual Conference 2019: Implementing Circular Value ChainsBrussels, Belgium 

21 March 2019, The Telegraph Plastic Sustainability Summit, London, England  

21 March 2019, International conference: Which sustainable future for plastic?Mons, Belgium     

20 – 22 March 2019, 19th International Automobile Recycling Congress IARC 2019, Vienna, Austria

27 – 28 March 2019, 6th World Elastomer Summit, Lyon, France 

1 – 2 April 2019, 12th World Congress and Expo on Recycling, Paris, France 

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