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May 2019


Green Alley Award application phase launched
Brexit and REACH
Landbell Group at edie Live 2019

Interview with Lorretta Jones, Regulatory Affairs Officer, H2 Compliance
European Commission publishes evaluation report on Batteries Directive
Focus on France

Focus on Georgia
Modulated fees discussed at Packaging Waste and Sustainability Forum
EERA: High energy batteries pose serious fire risk to recyclers
New calculation method for packaging waste

Timetable for India plastics restriction
UNEA calls for end to throwaway society

EU proposes data check for all chemicals above one tonne by 2027
ECHA begins consultation on microplastics restriction
South Korea’s cabinet approves chemical tracking system

Study on the digitization of waste management in Germany

EPBA released annual report on the collection of waste portable batteries
Plastics industry: Reclassification of titanium dioxide could undermine EU plastics strategy

Upcoming European elections to bring a wind of political change


Green Alley Award application phase launched 

With double the amount of applications already received compared to the same time last year, the popularity of the Green Alley Award continues to grow. Startups and entrepreneurs with digital circular economy solutions, recycling solutions or ideas for waste prevention are invited to submit their applications by 25th June 2019. A committee of experts will then analyse each business proposal and choose the six finalists who will appear at the Grand Final in Berlin. 

One expert is Olli Alanen who manages compliance services for Landbell Group in the Nordics and has supported the award for the last four years: “The Green Alley Award is an event that I very much look forward to each year. I have already got to know some great startups that are based here in the Nordics, such as Sulapac and RePack, and I hope to see many more Nordic startups applying this year!” 

Richard Dove, a Landbell Group packaging specialist in the UK, will be joining the expert committee for the first time this year: “After attending last year's awards ceremony I'm really excited to join the selection committee this year. I want to see what new ideas are being developed in our industry to improve sustainability and solve environmental problems."

Click here to apply for this year’s Green Alley Award
Contact Landbell Group here

Brexit and REACH 

The UK withdrawal from the European Union (EU) has been postponed until 31 October 2019, at the latest. The option exists for the UK to leave earlier if the current exit deal is adopted by the UK parliament at an earlier date. 

It is expected that the European Chemicals Agency (ECHA) will extend their window for UK manufacturers to transfer registrations to EU-27 Only Representatives (OR) beyond the current deadline of 12 April. EU-27 companies who source substances from UK based suppliers are advised to engage with their supply chain to ensure uninterrupted REACH compliance after the UK’s exit. The most likely solutions will be (a) the EU-27 importer from UK REACH registers the substance, (b) the UK manufacturer appoints an OR to REACH register the substance or (c) the EU-27 importer changes to another REACH registered supplier. These solutions must be in place immediately after the UK’s exit from the EU. 

The deadlines for UK companies importing into the UK will also shift in line with this new proposed exit date:
  • UK-based authorisation holders must notify and claim these Authorisations within 60 days of exit.
  • UK-based REACH registration holders must notify and claim these registrations within 120 days of exit.
  • UK-based importers from the EU/EEA, currently Downstream Users under REACH, must notify the UK authorities of these imports within 180 days of exit.
  • Non-UK manufacturers may appoint a UK-based OR to notify the UK authorities of these imports within 180 days of exit.
Landbell Group company, H2 Compliance ran a webinar on Brexit and REACH on Tuesday 30 April. Following the recent extension to Brexit, the webinar highlighted important deadlines and explained what companies now need to do in order to remain compliant.

Contact Landbell Group here

Landbell Group at edie Live 2019 

Landbell Group will take part at edie Live in Birmingham on 21 and 22 May 2019. edie Live is the leading UK event connecting energy, sustainability and resource professionals with the information, ideas and suppliers that they need to make their businesses more sustainable.  

Three specialists from Landbell Group in the UK will host advice clinics on international producer compliance, where they will explain to businesses making and distributing products how to reduce the complexity of extended producer responsibility legislation, and provide support on other product and packaging related requirements. The experts will offer guidance on obligations and discuss established and emerging producer responsibility legislation around the world.

For more information, and to book a slot at an advice clinic, click here
Contact Landbell Group here

Interview with Lorretta Jones, Regulatory Affairs Officer, H2 Compliance 

What’s your job at Landbell Group? 
I’m a regulatory affairs officer and my role is so varied! I mainly work in the team supporting clients with their compliance under the Biocidal Product and the Cosmetic Product Regulations. I also hold the study monitor role, which involves managing our third-party laboratory testing programme where we determine the toxicological, eco-toxicological, physical and chemical properties of substances on behalf of our clients.I am also working more and more on the communications that we offer to our clients, managing our monthly regulatory updates newsletter and organising webinars. 

What are your most important tasks and challenges? 
When you work in compliance, everything that you do is important! On the cosmetic product side, a lot of ingredients can be included in a type of product, therefore I regularly review the regulation to ensure that none of our clients’ products contain substances that are prohibited or have restrictions.Staying on top of the biocidal product regulation – which was implemented in 2013, replacing the Biocides Directive that had been in force since 2000 – is a job in itself! Almost the entire supply chain – from active substance and biocidal product manufacturers to product users – have a role to play in ensuring compliance. Until an active substance is given an approval date by the European Commission, the “old” Directive effectively still applies creating a two-tier system which leads to lots of confusion. My job is to simplify and explain the process to clients and colleagues alike. 

How did you come to work for Landbell Group? 
I started working for the pan-European team at DHL EnviroSolutions in July 2015, providing compliance services to clients under the WEEE, Battery and Packaging Directives. Then, following the launch of the strategic partnership with DHL Supply Chain, I moved to Landbell Group in January 2017.It was a fantastic opportunity to join a large company specialising in the compliance services that we offered. In January 2018, I decided to dust off my Master’s degree in chemistry and joined the chemicals team. Two years on, it’s great to be part of a company with such positive plans and ambitions for the future. 

What do you do for the environment in your private life?
I’ve made little changes, such as bringing my own shopping bags, carrying a refillable water bottle and using public transport, but I really admire those people who make complete overhauls like owning an electric car or only sending one small bag of waste to landfill each year.I also like shopping at second-hand charity shops and vintage markets for homeware and furniture. I have a large beautiful glass vase, which is such a statement piece, and it cost me less than £3! 

European Commission publishes evaluation report on Batteries Directive 

The European Commission has finally completed its evaluation of the Batteries Directive. The accompanying report was published in early April and finds that the collection of waste batteries within the European Union is insufficient, with minimum collection targets for waste portable batteries, as well as minimum recycling requirements, falling short of the Directive’s goals. In addition, the evaluation concludes that the Directive lacks a mechanism to cope with technical developments, like the increased use of lithium-ion batteries over the last ten years. 

The evaluation is based on a study which was completed by Trinomics and Öko-Institut last autumn. Despite the above mentioned shortcomings, the study found that the principle of extended producer responsibility (EPR) for portable batteries has proven to be effective.  

Based on the findings of the evaluation, the Batteries Directive will likely be revised in the next legislative period. The recast will probably consider additional targets for collection and recycling.

Please find the evaluation report here

Focus on France 

The Circular Economy Roadmap, which the French government published on 23rd April 2018, introduces 50 measures to halve the amount of waste that is sent to landfill and recycle all plastic by 2025. The measures include a mandatory reparability label for electrical and electronic equipment and a nationwide drive to accelerate the collection of recyclable packaging, plastic bottles and cans.  

The Circular Economy Roadmap also proposes to replace the Green Dot for packaging, which confuses consumers and provides no information on recyclability, with the Triman logo (see example on the side). From 2021 onwards, the Triman logo would then need to appear on obligated household packaging and products, along with information on sorting or the materials used in the packaging. To avoid confusing the consumer, the use of other symbols or labels will be prohibited. 

Further proposals in the roadmap include expanding existing extended producer responsibility (EPR) legislation for diffuse hazardous waste and end-of-life vehicles, and introducing new EPR legislation to cover the following products:
  • Toys, sports and leisure equipment
  • DIY and gardening equipment
  • Packaging (from cafes, hotels and restaurants)
  • Cigarettes
The proposals in the Circular Economy Roadmap have the potential to dramatically change EPR legislation in France and, without harmonization at EU level, the Triman logo could impede the free movement of goods across the European market. Landbell Group monitors existing and emerging legislation for producers, as well as upcoming regulatory changes throughout the world, and will follow the proposed changes in France closely.  

Contact Landbell Group here

Focus on Georgia  

The country of Georgia will introduce extended producer responsibility (EPR) legislation by the end of this year. The comprehensive new regulations will cover packaging waste, waste electrical and electronic equipment, used tyres, end-of-life vehicles, used oils, and waste batteries. Under Georgia’s Waste Management Code, manufacturers and the companies that market their products will be responsible for mitigating the negative environmental impacts associated with the manufacturing, use, recovery and disposal of these goods. 

EPR is a new concept in Georgia, and will be supported by the necessary legal framework, as well as increased public and private sector awareness. ”In Georgia, the situation in waste management is improving year by year. The waste management code is accepted. I would like to highlight the support of the European Union and international donor organizations for Georgia in the consultations. We hope to see tangible progress in waste management in Georgia in the near future,” said Georgia’s Deputy Minister of the Environment, Giorgi Khanishvili. 

Georgia’s environment ministry is currently drafting the new legislation that will come into force in December and Landbell Group is monitoring developments.

Contact Landbell Group here

Modulated fees discussed at Packaging Waste and Sustainability Forum   

The Packaging Waste and Sustainability Forum took place from 2-3 April in Brussels, bringing together leaders in recycling and sustainability, as well as some of the biggest manufacturers in Europe. Landbell Group also attended the forum, which was opened by the European Commission. The forum gave participants the opportunity to hear from organizations at the cutting edge of waste reduction and sustainability who covered new developments in Europe and the rest of the world. The forum was preceded by an extended producer responsibility (EPR) workshop on 1st April. 

The three-day discussions were dominated by the new European rules stipulated by the Waste Framework Directive, including modulated fees for packaging EPR and the new calculation methods for the packaging recycling targets. National ministries and authorities also provided updates: the German environment ministry presented the new German packaging law; DEFRA described its packaging consultation which aims to radically change the EPR system in the UK; and the Austrian clearing house explained the enforcement setup in Austria. Larger producers, packaging producers and cities also presented their initiatives.

EERA: High energy batteries pose serious fire risk to recyclers 

The European Electronics Recyclers Association (EERA) has conducted a survey among its members to gain insight into the issue of fires and other incidents caused by damaged batteries. The survey results highlight substantial risks faced by recyclers, and a need to better train and prepare for such hazards in the future. 

The survey uncovered that 80% of EERA members experienced serious fires caused by batteries, with two thirds of those considered major incidents. EERA has said that most fires start during unloading or storage, making it clear that a problem exists in the collection of waste electrical and electronic equipment (WEEE). The European Union does have legal requirements in place for the collection and transport of lithium batteries - The European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) - but the report claims that these requirements are largely ignored.

EERA has stated that its members are not fully aware of the risks associated with the collection of these batteries, which leads to reluctance to follow the ADR requirements. EERA has also called for producers, compliance schemes and collection centres to follow the ADR rules, stressing that compliance is not only a safety issue, but will lead to lower costs related to fire prevention, health and safety, and insurance. 

Landbell Group has transported more than 50,000 tonnes of batteries across Europe under ADR regulations and has a specialist team dedicated to battery collection, transportation and treatment.

Contact Landbell Group here

New calculation method for packaging waste

The Member States of the European Union have agreed on a new methodology for the calculation of recycling rates for packaging waste. The Commission Implementing Decision amends the existing provisions from 2005 and brings them in line with the new requirements of the Directive on Packaging and Packaging Waste which was amended last year. 

The new provisions specify the methodology for calculating whether the recycling targets have been reached by explaining, for example, how to take into account reusable sales packaging or wooden packaging repaired for reuse. To ensure accurate, factual reporting, the new method is much stricter and also specifies the calculation points for the main packaging materials and recycling operations to ensure that recycling rates are comparable among Member States. In addition, the new methodology lays down the format to be used by Member States when reporting data on packaging waste to the Commission. 

The so-called “Commission Implementing Decision amending Decision 2005/270/EC establishing the formats relating to the database system pursuant to Directive 94/62/EC of the European Parliament and of the Council on packaging and packaging waste” was approved by a vast majority of Member States and was officially adopted by the Commission and was published in the Official Journal on 26th April (2019/665).

Find the Implementing Decision here

Timetable for India plastics restriction  

India’s Ministry of the Environment, Forest and Climate Change has announced that its upcoming ban on plastic waste imports will come into effect at the end of August. The ban follows a similar move by China which outlawed the import of lower quality plastic waste. India’s imported plastic waste largely comes from western economies, with 25% originating from the United States and 40% from Europe. 

While the 250,000 tonnes of plastic waste imported into India per year pales in comparison to the approximate 7 million tonnes per year into China, the ban will increase the pressure on western nations to tackle their growing plastic waste problems.  

From 31 August, all loopholes will be closed, and Indian companies will no longer be allowed to import plastic waste into the country.

UNEA calls for end to throwaway society  

The fourth United Nations Environment Assembly (UNEA), which took place in the Kenyan capital of Nairobi from 11-15 March 2019, passed 23 new resolutions to promote sustainable consumption and production worldwide. The assembly brought together leaders, environment ministers and 5,000 delegates from around the world to discuss new solutions to tackle global environmental issues. 

Plastic waste was central to the discussions, with leaders working together to devise a comprehensive plan to eliminate the growing problem of marine plastic waste. While resistance from a number of states prevented the passing of a new mandate, Germany and other ambitious states will continue the discussions started in Nairobi. 

Environment Secretary Jochen Flasbarth, who headed the German Delegation, described the progress made at the talks: “The fourth UNEA has created a strong tailwind for the fight against plastic waste. We will invite the states that are in favour of an internationally binding agreement on plastic waste to jointly draft the next steps towards the plastic convention.”

EU proposes data check for all chemicals above one tonne by 2027  

The European Chemicals Agency (ECHA) and the European Commission will publish an action plan in June that will call for the screening of data for all REACH registered substances above one tonne by 2027. The new plan aims to assess hazard data to see whether current requirements under REACH are sufficient for all substances on the European market. 

ECHA Executive Director, Bjorn Hansen explains that the 2027 deadline will not signal the end of ECHA’s work: “After 2027, there will still be lots to do because, of course, there are lots of chemicals that enter the market. We will continue our work but it will be less intensive.” 

At the REACH 2018 deadline, the number of substances placed on the market between 1 to 100 tonnes per year amounted to 11,114 - close to half of the 22,257 substances registered overall.  

The European Chemical Industry Council (Cefic), has also announced that it is developing an action plan to better address data gaps in REACH dossiers. "We are looking into the exact reasons as to why, despite the industry’s efforts to provide the necessary data, the evaluation done by ECHA and national authorities has found shortcomings in many dossiers," said a representative from Cefic. Once finalized, the action plan will be published on Cefic’s website. 

Landbell group company, H2 Compliance will host a webinar on Tuesday 25th June entitled “What next for REACH?” One year after the REACH registration deadline has passed, the webinar will look at key learnings and dossier maintenance, as well as risk management. Register for the webinar here.

Contact Landbell Group here

ECHA begins consultation on microplastics restriction 

The European Chemicals Agency (ECHA) has started a public consultation on its restriction proposal for intentionally added microplastics in products. The consultation period runs until 20 September. ECHA proposes to ban certain consumer and professional uses of intentionally added microplastics, while other uses would be subject to labelling/information requirements and annual reporting. Many applications are covered including pharmaceutical, cosmetics, detergents, paints, coatings, maintenance products, and agriculture.  

ECHA’s Risk Assessment (RAC) and Socio-economic Analysis (SEAC) Committees will review the proposals before sending their opinions back to the Commission in early 2020. The Commission will then propose to amend the REACH Regulation if the restriction meets the legal requirement.
Definition: Microplastics are described as solid polymer containing particles to which additives or other substances may have been added, and where at least 15% w/w of particles have:
  • All dimensions 1nm ≤ X ≤ 5mm or
  • For fibres, a length of 3nm ≤ X 15mm and a length to diameter ratio of > 3 

South Korea’s cabinet approves chemical tracking system  

The South Korean cabinet has approved an amendment to the Chemical Control Act (CCA) that calls for the introduction of a comprehensive chemical tracking system. The revisions to the act, which was first introduced last May, has been met with concerns from industry. 

The chemical tracking system will introduce a 15-20 digit code that will indicate:
  • whether the chemical is toxic;
  • the reporting year;
  • information on the substance form, and whether it is a mixture;
  • serial number;
  • verification number; and
  • the country of manufacture.
In its annual National Trade Estimate Report, the US raised a number of concerns regarding the new tracking system, in particular how it will effect confidential business information (CBI). South Korea’s Ministry of Environment responded to US concerns and stated that the revisions to the Act include multiple measures to protect CBI. 

Landbell group company, H2 Compliance will host a webinar on Wednesday 29th May entitled “Chemical Regulation in the Rest of the World”. The webinar will explore some of the countries, including North America and South Korea, which already have or soon will have chemical regulations in place. Register for the webinar here

Study on the digitization of waste management in Germany  

Waste and resource management company, Resourcify, has lent its support to a Master’s thesis at the University of Oldenburg which carried out a qualitative study into the state of digital transformation in waste management in Germany. The study has uncovered that there is no clear distinction between “digital” and “analogue” waste management, although the degree to which waste management companies have undertaken this digital transformation varies greatly.  

The survey also shows that companies are generally aware of the importance of digitization, although they are more likely to employ new technologies in internal capacities rather than for customer focused activities. Companies using digitization for customer interaction and services are considered to be early adopters in this regard. The survey looked at waste disposal companies with a size between 21-1000 employees and focused on private waste disposal companies that deal with commercial customers. The study found that the size of the organization does play a role, with smaller companies often lacking the capacity to engage in digital transformations. 

Landbell Group’s Circul8 is a cloud-based software suite for the Circular Economy which is developed to manage products, waste and materials. It is deployed in 20 countries, across 4 continents, managing eight million tons of waste and €2.7B of revenue.   

Contact Landbell Group here

EPBA released annual report on the collection of waste portable batteries  

On 12th March 2019, the European Portable Battery Association (EPBA) released the 6th update of its annual report on waste portable battery collection. The report compiles data from the 28 Member States of the European Union, as well as Norway and Switzerland.  

The report, based on 2017 data, showed that 18 out of 28 EU Member States met or exceeded their 45% collection target. Additionally, the report shows that collection results for 12 Member States were down on 2016, with one explanation being that, while many countries did collect more spent batteries, those numbers were offset by an even higher number of batteries that were put on the market. This highlights the need for a new calculation methodology to better represent the actual status of the market. 

“The findings of the 2017 update are in line with the previous annual updates and underline again the need for a proper evaluation of the calculation methodology,” said Hans Craen, Secretary General of EPBA. 

The overall quality of the data comes under question in two particular countries, with Croatia including volumes from previous years, and Slovakia’s reported data also raising questions.

Find the full report here

Plastics industry: Reclassification of titanium dioxide could undermine EU plastics strategy 

The European Commission’s plans to classify common whitener titanium dioxide as a carcinogen could have far reaching effects on the plastics waste and recycling industry, according to a new study commissioned by the plastics industry. The white pigment is a common additive in paints, cosmetics and medicines, and is present in almost all processed plastics in Germany, with close to half of them containing more than one percent titanium dioxide. 

Representatives from the plastics industry are opposed to the reclassification, stating that strict limits and regulations already exist to ensure the proper and safe use of titanium dioxide. They also pointed to the argument that several long term studies have failed to identify health risks for workers handling the substance. 

The new study states that the reclassification of titanium dioxide as a carcinogen would undermine the European Union’s plastics strategy, as all products featuring more than one percent titanium dioxide would be treated as hazardous waste and therefore not be eligible for recycling.

Download the study here (in German)

Upcoming European elections to bring a wind of political change 

This year will be one of major political change for the European Union. The upcoming elections in May will bring a whole new raft of individuals and alliances into the European Parliament, and there will be a new European Commission with possibly a different long-term vision and priorities. 

The European elections take place between 23rd and 26th May. The European People’s Party (EPP) is expected to remain the largest group, but will probably need to rely on cooperation with both the Socialists & Democrats (S&D) and the Alliance of Liberals and Democrats for Europe (ALDE). Many of the key people in the circular economy are running again and are likely to be re-elected, e.g. Simona Bonafè, rapporteur for the Waste Framework Directive which was amended last year, and Frederique Ries, rapporteur for the Directive on single-use plastic which is expected to be formally adopted very soon. 

The composition of the new European Parliament’s committees will be defined in July, when the Parliament will also vote on the committee chairs and the President of the new European Commission. After the appointment of the Commissioners and the corresponding portfolios by the President elect, the new Commission needs to be formally approved by both the European Parliament and the Council of the European Union before officially starting work in November. 

16 – 17 May 2019, 4th Circular Change Conference, Maribor, Slovenia

3 – 5 June 2019, 3rd World Circular Economy Forum in Helsinki, Finland 

4 June 2019, European Chemical Recycling Conference 2019, Brussels, Belgium 


12-13 June, Resourcing the Future 2019, London, England

13 – 14 June 2019, 11th World Congress and Expo on Recycling, Edinburgh, Scotland

18 – 20 June 2019, Circularity, Minneapolis, Minnesota

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