Presentation Conference IERC Salzburg on different interpretations of Waste Shipment Regulation and brominated flame retardants.

1. A discussion around how flame retardants
might endanger reaching the WEEE targets
- EU Regulation is choosing between options? -
Chris Slijkhuis

2. Agenda
The origin of the problem
Why recycling of tech plastics from WEEE and ELV‘s
Why exporting of plastics to China?
Raw Materials from E-Waste
Flame retardants – the EU ENV discussion and options
Processing plastics in China by MBA Polymers
Conclusions & final comments
Plastics and Electronics are Global businesses

3. Stopped containers in the Antwerp Harbor
Suddenly
S dd l containers were stopped i th A t
t i t d in the Antwerp h b
harbor
Stoppings based upon a statement of the Flemish OVAM
Statement of Flemish OVAM to Inspection
• E-Waste plastics can have Br-FR‘s
• These plastics with Br-FR‘s are hazardous
p
• No export out of Flanders, unless notification
• No export when recycling for electronics
• No export at all outside EU
Containers were returned to origin
Argumentation prepared on basis
• 1013/2006
Link

4. Mixed WEEE plastics can always have Br-FR‘s

5. Export was allowed after local inspections
We
W were able t lib
bl to liberate all containers placed at custody
t ll t i l d t t d
But huge costs and efforts were needed
So we have decided to ask the EU for clarification that
• E-Waste plastics are green listed plastics
• Export is allowed within and outside the EU
p
• Only group of Polybrmonicated Biphenyls (PBB) is hazardous
• That shredded plastics cannot follow the EU code 16 02..
• That shredded plastics are to be exported as B3010 and 19 12 04
Correspondents meeting EU 1013/2006 took place in September
And discussions still ongoing
• At the moment that this presentation is made
• Correspondents meeting to take place on Jan. 15th 2009

6. Why recycling of tech plastics from/for electronics
Without plastics recycling EU recycling targets impossible
• WEEE and ELV directives are clear in their targets
• WEEE – 65 % for Small Domestic Appliances
• ELV – 85 % as from 2015
Increasing pressure from the market and environment
• NGO‘s like Greenpeace are putting industry under pressure to act
• Consumers increasinlgly become aware
• EU Frame Work and other directives support this
• REACH helps to create the framework
Replacing virgin plastics with recycled makes sense
• Recycled plastics were traditionally „down-cycled
down cycled“
• Best available technology now exists to recycle to high standards
Plastics recycling... huge environmental benefit
recycling

7. The environmental benefit
approx. 900 liter crude oil
approx. 2 tons e-waste
approx. 14.000 kWh
approx. 1000 kWh
pp
OR
<10% of the water consumption
<10% of the energy consumption
gy p
2-3 kg reduction of CO2 emissions per kg of recycled plastic

8. Electronics is Global, so MBA Polymers is also Global

9. The E-Waste Supply Cycle focussing on plastics
De-Pollution
Shredder Ferrous-Metals
Size d i
Si reduction,
liberation and
Non-FE Non-Ferrous-Metals
separation
Separations
Smelters
S lt
Separate Non-
Plastic Items
Further Separation Plastic/non-Plastic
Mixed Plastic Rich E-Waste

10. Options for Plastics-Rich Streams after Recycling
Landfilling:
df ll
banned in some countries, costs increasing, questions about pollution, lose
important raw material and impossibility to reach targets for recycling of E-
Waste and ELV’s
Incineration:
(in
(i many forms) costly and b
f ) tl d becoming more-so, questions about air pollution,
i ti b t i ll ti
capacity issues, lose important raw material and impossibility to reach targets for
recycling of E-Waste and ELV’s
Recycling in line with the European Standards:
large customers require a more reliable and dependable solution, customers for
t ese plastics can push eedstoc
these plast cs ca pus feedstock to e cycle suppliers, but need la ge volu es a d
e-cycle suppl e s, eed large volumes and
ideally global presence to do this successfully. All MBA Polymers plants worldwide
work on the basis of the same technologies and separate Br-FR’s.
Let‘s have a closer look at the materials

11. The Raw Materials
Small domestic appliances Fridges
ICT Plastics (with Br-FR‘s) CRT Plastics (with Br-FR‘s)

12. The avg. composition of the Sourcing Material EU
Ferrous & N-Ferrous
1%
Fluff/Foam
Other Plastics Wires & Elect Parts
17% 4% 1% Wood
Other Non-Plastics
Non Plastics
Rubber 3% 1%
3% Fines
1%PP
PVC
3%
1%
POM
1%
PC-ABS & PC
6%
HIPS
PE
27%
1%
ABS-FR
3%
PPO
2%
ABS
HIPS-FR
24%
2%

13. Brominated Flame Retardants
Those Br-flame retardants that are Substances of Concern
• PBB Polybrominated Biphenyl – POP and PIC listed
• PBB is the only Br-FR that is nominatively mentioned in 1013/2006
• PBB is chemically a different family of substances than PBDE‘s
• Octa-Poly Brominated Diphenylether PBDE – not yet POP or PIC listed
• Penta- Poly Brominated Diphenylether PBDE – not yet POP or PIC listed
One Br-Flame retardant with some level of discussion
• Deca PBDE – not POP nor PIC listed
• Has been in use for a long period of time
• Controversial EU court decision earlier this year
• EU Stakeholder Consultation (RoHS) has been started, outcome will take time
All other Brominated Flame Retardants are of no concern
• These involve most of the Brominated Flame retardants found in E-Waste
Most Br FR‘s are of no concern
Br-FR‘s

14. TAC guidelines regarding Annex II – Br- FR‘s
WEEE Directive Annex II requires separation Br-FR‘s
Guidance Document TAC Annex II WEEE Directive
• Manual, mechanical or other separation of Br-FR‘s
• To result in environmentally safe treatment
• Not necessarily at first stage of treatment
• To result in an identifyable stream at end of process

15. Brominated Flame Retardants and new products
Brominated Flame Retardants are accepted to be used
• Br-FR’s are required In many applications – not only electronics
The l B FR‘ li t d in
Th only Br-FR‘s listed i REACH as restriced are:
t i d
• PBB Polybrominated Biphenyl
• Octa-Poly Brominated Diphenylether PBDE at a level of > 1000 ppm &
• Penta
Penta- Poly Brominated Diphenylether PBDE at a level of > 1000 ppm
So all other Br-FR‘s should be allowed to be transported
• And these Br-FR‘s are the majority of the Br-FR‘s found in E-Waste plastics
j y p
• This is what is the basis of the global investments of MBA Polymers
Only a few Br Flame Retardants are limited
Br-

16. Brominated Flame Retardants in E-Waste plastics
Poly-Brominated
Poly Brominated Biphenyl (the family of the PBB‘s)
• Not found at levels higher than the detection limits in all samples
• This coincides with the findings of the MBA Polymers analyses
• PBB cannot be found in E-Waste plastics
E Waste
Poly-Brominated Di-Phenyl-Ethers (the family of the PBDE‘s)
• Octa Poly
Octa-Poly Brominated Diphenylether PBDE always at a levels of < 1000 ppm
• Penta- Poly Brominated Diphenylether PBDE always at a levels of < 1000 ppm
• Hepta and Deca –PBDE‘s can be found at higher levels
All other brominated flame retardants
• Can be found at higher levels
• TBBPA and it‘s derivates represent largest volume of Br-FR‘s used and found
• Therefore a total Br content approach cannot be chosen
Br-content
• And a detailled analysis must form the basis of any decision, if any.
Most Br FR‘s are of no concern
Br-FR‘s

17. Only PBB is nominatively stated in 1013/2006
PBB is a diferent type of substance than PBDE

18. EU Options proposed in Correspondance Meeting
Option1: plastics with Br-FR to be notified in EU and export ban non OECD
Br FR
• Cannot be applicable as most Br-Fr‘s are non-hazardous substances
• PBB cannot be found in E-Wate plastics at levels > 50 ppm
• Octa-and Penta-PBDE can not be found in quantities > 1000 ppm each
Option 2: Threshold level total Bromide content
• Not applicable as most Br-FR‘s are perfectly acceptable compounds
Option 3: New Annex IIIB entry (notification OECD and non-OECD)
• Proposed by several EU countries as solution to the problem
• Of course PBB at the current level of <50 ppm
• At max acceptable if only Octa and Penta PBDE are limited at each 1000 ppm
Octa- Penta-PBDE
• And if enforced in all EU member States in the same way
Option 4: „Risk-based“ approach on total PBB and PBDE (notification)
p pp ( )
• Acceptable, but again with the same remarks as option 3.
Option 5: Greenlisting all plastics from consumer E-Waste
and all plastics from business applications and CRT as 4
4.
• Acceptable, but again with the same remarks as option 3.

19. High Tech Recycling in China
The GMP - MBA Polymers plant in the Pearl River Delta near Guanzhou

20. Goods-In, Analysis & Pre-processing
Sourcing & Goods In
Goods-In
• Material Handling
• Assaying
• Material Analysis
Pre-Processing
• Taking out remaining metals
• Cleaning material of minerals (glass, stones, dust)
• Eliminating organic fractions such as wood and rubber
g g
Size reduction to a standard particle size
Conveying plastic material into high tech seperations
l l h h h

21. High Tech Separations & Extrusion/Compounding
Cleaning plastics
High Tech
High-Tech Separations
• Obtaining PP, ABS and PS
• Separating Br FR’s
Br-FR s
• In three grades
• Injection Moulding
• Extrusion
• General Purpose
High quality extrusion and compounding
• RoHS compliant products

22. Laboratory for detailled process control
Incoming Material Analysis
• Yield & contaminations
Process Control
• Numerous checkpoints
• In-time feed-back cycles
• Purity
P it control fi l products
t l final d t
Final products Quality Control
• Each big bag is quality controlled
• MFI, Izod and Tensile Strength

23. High Tech Applications for End-Products
Made from Post-Consumer Plastics

24. Summary
The discussion on export of E-Waste plastics is not only
important to MBA Polymers; it is for the electronics
recycling industry at large.
The recycling quota of the EU will not be met if plastics
cannot be recycled.
Many brominated flame retardants can continue to be
used for housings of electronics
electronics.
Recycling is preferable to incineration or land-filling
from both economic and environmental standpoints.
f b h d l d
The CO2 balance advantage should be taken into
account in this debate.

25. Supply Chain to Supply Cycle......for the sake of Environment