Green Paper - Environmental issues of PVC
Date: 2000-07-26
Institutions: European Commission
Subjects: environmental impact, health risk, plastics, sustainable development

COMMISSION OF THE EUROPEAN COMMUNITIES

Brussels, 26.7.2000
COM(2000) 469 final

GREEN PAPER

Environmental issues of PVC

(presented by the Commission)

TABLE OF CONTENTS

1.

2.

Introduction ................................................................................................................. 3

The PVC industry and its products............................................................................... 3

2.1. PVC material and its applications.......................................................................... 3

2.2. Production processes of PVC and PVC compounds................................................ 4

2.3.

Structure and description of the PVC industry........................................................ 6

3.

The use of additives in PVC......................................................................................... 7

3.1. Range and types of additives .................................................................................. 7

3.2.

Stabilisers .............................................................................................................. 8

3.3. Plasticisers .......................................................................................................... 13

4.

The waste management of PVC ................................................................................. 15

4.1. Current situation and future developments........................................................... 15

4.2. Mechanical recycling ........................................................................................... 17

4.3. Chemical recycling .............................................................................................. 22

4.4. Other recycling and recovery technologies including co-incineration .................. 24

4.5.

Incineration ......................................................................................................... 25

4.6.

Landfill ................................................................................................................ 31

5.

6.

Other horizontal aspects on PVC ............................................................................... 33

Conclusion................................................................................................................. 34

2

GREEN PAPER

Environmental issues of PVC

1.

INTRODUCTION

The Commission has committed itself to assess the impact of PVC on the
environment, including related human health issues, in an integrated approach. In the
Proposal for a Directive on end of life vehicles1, it is stated that “the Commission will
consider the evidence regarding the environmental aspects relating to the presence
of PVC in waste streams; on the basis of the evidence, the Commission will review its
policy regarding the presence of PVC in waste streams and will come forward with
proposals to address problems which may arise in this regard.” In the Council
Common Position on that Proposal2, it is further stated that “the Commission is
currently examining the environmental impacts of PVC. The Commission will, on the
basis of this work, make proposals as appropriate as to the use of PVC including
considerations for vehicles”.

PVC has been at the centre of a controversial debate during much of the last decades.
A number of diverging scientific,
technical and economic opinions have been
expressed on the question of PVC and its effects on human health and the
environment. Some Member States have recommended or adopted measures related
to specific aspects of the PVC life cycle. These measures are not identical and some
of them may have consequences for the internal market. An integrated approach is
therefore necessary to assess the whole life cycle of PVC in order to develop the
necessary measures to ensure a high level of protection of human health and the
environment as well as the proper functioning of the internal market.

The two objectives of this document are, firstly, to present and assess on a scientific
basis, the various environmental issues including related human health aspects that
occur during the life cycle of PVC and, secondly, to consider, in view of sustainable
development, a number of options to reduce those impacts that need to be addressed.
This should serve as a basis for a consultation with stakeholders in order to identify
practical solutions to health and environmental issues raised by PVC.

2.

THE PVC INDUSTRY AND ITS PRODUCTS

2.1.

PVC material and its applications

Polyvinyl chloride (PVC) is a synthetic polymer material (or resin), which is built up
by the repetitive addition of the monomer vinyl chloride (VCM) with the formula
CH2=CHCl. PVC has thus the same structure as polyethylene except for the presence
of chlorine. The chlorine in PVC represents 57% of the weight of the pure polymer

1

2

COM (97) 358 final
EC 39/1999

3

resin. 35% of chlorine from the chloralkali electrolysis eventually ends up in PVC,
which thus constitutes the largest single use.

Pure PVC is a rigid material, which is mechanically tough, fairly good weather
resistant, water and chemicals resistant, electrically insulating, but relatively unstable
to heat and light. Heat and ultraviolet light lead to a loss of chlorine in the form of
hydrogen chloride (HCl). This can be avoided through the addition of stabilisers.
Stabilisers are often composed of salts of metals like lead, barium, calcium or
cadmium, or organotin compounds3.

The mechanical properties of PVC can be modified through the addition of low
molecular weight compounds that mix with the polymer matrix. Addition of these so-
called plasticisers in various amounts generates materials with an important
versatility of properties that has lead to the use of PVC in a vast range of
applications. The main types of plasticisers used are esters of organic acids, mainly
phthalates and adipates4.

The main distinction between the numerous applications is between « rigid PVC »
(accounting for about two thirds of total use) and « flexible PVC » (accounting for
about one third).

The following table presents the main applications of PVC in Europe and the
percentage of overall use. The great number of applications is characterised by a
wide range of lifetimes ranging from several months to more than 50 years for some
construction products. The main applications of PVC in Europe are in the building
sector, which accounts for 57% of all uses and where products also have the longest
average lifetimes.

Table 1: Main use categories of PVC in Europe (1999)5

Use / application
Building
Packaging
Furniture
Other household appliances
Electric/Electronic
Automotive
Others

Percentage
57
9
1
18
7
7
1

Average life-time (years)

10 to 50
1
17
11
21
12
2-10

2.2.

Production processes of PVC and PVC compounds

Mass production and use of PVC took off in the 1950s and 1960s, whereas the first
industrial production started in the 1930s.

World production of PVC today is at more than 20 million tonnes per year - up from
3 million tonnes in 1965 - which corresponds to about one fifth of the total plastic
production. PVC is thus one of the most important synthetic materials. Production is

3

4

5

More details and quantities will be discussed in section 3.
More details and quantities will be discussed in section 3.
Prognos, Mechanical recycling of PVC wastes, Study for DG XI, January 2000

4

mainly located in the US, Western Europe and Asia. Production in Western Europe
in 1998 was 5.5 million tonnes (about 26% of the world production). Average growth
rates of PVC production in recent years have been between 2 and 10%, with
differences per region (higher in Asia, lower in Europe) and per application (higher
for rigid, lower for flexible). Prices for virgin PVC are extremely cyclical due to
variations in supply and demand and prices for the raw materials.

Two main processes are used to produce PVC: suspension polymerisation of VCM
(80%) and emulsion polymerisation (10%).

The production of VCM from ethylene and chlorine, or ethylene and HCl
respectively, takes place to a great extent in closed industrial processes. Emissions of
chlorine, ethylene, ethylene dichloride, HCl, VCM and chlorinated by-products
including dioxines to the working environment or the outdoor environment can occur
(air and water). Several of these chemicals are well known toxic substances6and strict
emission control measures are therefore necessary. Several Community Directives
apply to PVC and VCM production processes7.

the protection of

the marine environment of

As in other sectors of the chemical
industry, continuous improvements in the
production processes have taken place over the years. Best available technologies for
the production of VCM and suspension PVC have been established, which have led
to the adoption of a number of relevant emission limits in OSPAR Decisions
(Convention for
the north-east
Atlantic)8. A voluntary commitment was already signed in 1995 by the Association
of European PVC producers (ECVM). In this industry charter for production of
VCM and PVC (suspension), strict emission limits for a number of chemicals were
set, which had to be complied with by 1998. Compliance was verified through an
independent audit, which attested an overall compliance of 88% with all standards.
ECVM has expressed its intention to achieve full compliance as soon as possible. In
addition to the charter for VCM and suspension PVC production, ECVM signed in
1998 a charter for the production of emulsion PVC with strict emission limits for
VCM to air and water, and VCM content of the final polymer. Those companies,
which, although already complying with existing national and local regulations or
requirements, do not yet comply with the stricter limits of the voluntary charter,
committed themselves to do so by 2003. An independent external verification is
scheduled for early 2004.

6

7

8

According to Dir. 67/548/EEC, VCM is classified as carcinogenic category 1, EDC as carcinogenic
category 2, HCl as corrosive and irritant to the respiratory system,
Protection of the health of workers exposed to vinyl chloride monomer. Council Directive 78/610/EEC
of 29.6.78 (OJ L 197 of 22.7.1978, p. 12)
The provisions of Directive 96/61/EC concerning integrated prevention and reduction of pollution,
Directive 76/464/EEC and 86/280/EEC on discharges of certain dangerous substances and Directive
84/360/EEC on the combating of air pollution from industrial plants apply to PVC and VCM production
processes. Directive 91/61/EC establishes the application of best available techniques (BAT) as the
general rule for emission limits. Information concerning BAT for large volume organic chemicals will
be published by the Commission in 2001/2002, as part of the BAT information exchange being
organised pursuant to Article 16 (2) of Directive 96/61/EC. It is possible that new emission limits will
then be adopted in accordance with Article 18 of the Directive.
Decisions 98/4 and 98/5 enter into force on 9 February 1999 for new plants and on 1 January 2006 for
existing plants. The Commission, in its Proposal for a Council Decision [COM(1999) 190 final],
proposes that these Decisions are approved on behalf of the Community

5

Raw PVC is processed into finished products in several steps. The addition of the
necessary additives is called PVC-compounding. PVC is a thermoplastic material,
i.e. upon heating it melts and can then be brought into many forms and shapes
through various processes. After cooling, the material regains its original properties.
A large number of different methods that use this principle are employed in the
transformation of PVC, notably extrusion, calendaring, injection moulding, blow
moulding, rotation moulding, thermoforming, and film blowing.

transformation, emissions of a number of
During compounding and further
dangerous substances and therefore exposure of workers can occur. Compounding of
PVC powder and additives (also in powder form or liquid) is usually carried out in
closed equipment. Exposure of workers can occur when dosing the compounds in the
mixer. This can be eliminated or reduced to a minimum in accordance with the
provisions of Council Directive 98/24/EC9on the protection of the health and safety
of workers from the risks related to chemical agents at work.

In cases of over-heating during conversion of PVC through heating, forming and
cooling, there is a risk of emission of a number of degradation compounds, where
HCl is the most important one. However, the amounts generated are small and have a
low potential of adverse effects on the environment. The amounts of VCM rest
monomer emitted during the conversion are considered to be very low10. The
emissions of stabilisers and plasticisers are also small if appropriate measures are
taken. In general, workforce protection measures have to be taken, in order to
comply with the existing legislation on workers and environment protection11.

2.3.

Structure and description of the PVC industry

Recent statistics produced by the PVC industry estimate that the total PVC producing
and transforming industry in Western Europe comprises more than 21.000 companies
with more than 530.000 jobs and a turnover of more than 72 billion
. The industry
can be roughly divided into four groups: PVC polymer producers, stabiliser
producers, plasticiser producers, and PVC transformers.

€

PVC polymer is produced by a relatively small number of companies, mostly located
in Europe, the US, and Japan. Production capacity in developing countries is growing
steadily as well. Annual consumption in Western Europe is slightly higher than
production, and since the early 1990s, imports have been higher than exports leading
to a small net import of about 230.000 tonnes in 1998 (when domestic production
was around 5.5 million tonnes)12. Several manufacturers are integrated in the
chlorine or petrochemical industry and also produce ethylene, chlorine and VCM
monomer. In 1999, there were 10 companies producing VCM and PVC, operating 52
plants on 40 sites in 10 Member States and Norway and employing about 10,000
people.

9

10

11

12

JO L 131 of 5.5.1998, p. 11
Danish Environmental Protection Agency, Environmental Project No. 313, Environmental Aspects of
PVC, 1995.
Danish Environmental Protection Agency, op.cit.
Source: ECVM, based on data provided by EUROSTAT.

6

Eleven European companies (22 plants) produce more than 98% of the stabilisers
sold in Europe. They employ around 5.000 people for a production of 160.000 tonnes
of stabiliser formulations and a turnover of about 380 million

€

.

In 1999 there were about 20 companies producing about 1 million tonnes of
the three biggest accounting for about 40% of overall
plasticisers in Europe,
capacity13. The number
is decreasing: smaller companies are abandoning the
products or are being bought by big companies. It is estimated that about 6,500
people are employed by this industry. The production trend from 1990 to 1995 was
an annual increase of 1.5%. Western Europe is a net exporter of plasticisers.

The transformation of PVC into final products, which requires two or three different
manufacturing operations, is essentially done in more than 21,000 small and medium
sized enterprises. Ninety per cent of these SMEs have less than 100 employees, 5%
have between 100 and 500 employees, and 5% have more than 500 employees. Table
2 summarises the information regarding the number of companies, production and
employment of the whole PVC industry chain.

Table 2: PVC industry: companies, production, employment14

Products
Total PVC

Flexible
products

Rigid
products

Companies

Production (tonnes) Employment

21,199

10,321

7,900,000

3,700,000

10,878

4,200,000

530,000

260,000

270,000

3.

THE USE OF ADDITIVES IN PVC

3.1.

Range and types of additives

In order to provide the range of properties needed in the finished products, PVC
polymer is mixed with a number of additives. Depending on the intended application,
the composition of the PVC compound (i.e. resin + additives) can vary largely due to
the different quantities of additives that are incorporated into the polymer as fillers,
stabilisers, lubricants, plasticisers, pigments or flame retardant. A very large number
of different formulations of PVC compounds are used to manufacture products. The
use of plasticisers (mainly phthalates) and stabilisers in rather high quantities
constitutes a specific characteristic of PVC manufacturing compared to other types of
plastics. All other types of additives are also used to varying extent with other plastic
materials.

The most important categories of additives, which need to be assessed scientifically
in terms of hazardous characteristics and risks to human health and the environment,
are stabilisers, in particular those containing heavy metals such as lead and cadmium,
and plasticisers, mainly the phthalates.

13

14

Information received from the European Council for Plasticisers and Intermediates
Information received from the association of European Plastic Converters (EuPC)

7

3.2.

Stabilisers

Stabilisers are added to the PVC polymer in order to prevent degradation by heat and
light. Different types of stabilisers are used and their content in the final product
varies according to the technical requirements of the intended application.

Lead stabilisers are currently the most widely used, in particular lead sulphate and
lead phosphite. About 112,000 tonnes15 of lead stabilisers were used in Europe in
1998, containing about 51.000 t of lead metal and representing 70%16 of the overall
stabiliser consumption. With an overall consumption of lead of about 1.6 million
tonnes in Europe in 199517, lead stabilisers thus account for about 3% of the total
consumption. Lead stabilisers are used mainly in pipes, profiles and cables.

Cadmium stabilisers are still being used by some producers as stabilisers in PVC
window frames, where their use is still permitted by Community legislation. In
Europe, use of cadmium has largely decreased from about 600 t/a in 199218 to 100 t/a
in 1997 and 50 t/a in 1998.

About 14,500 tonnes of mixed metal solid stabilisers and 16,400 tonnes of liquid
stabilisers were used in 1998 in Europe19,20. Among these types of stabilisers,
calcium/zinc and barium/zinc systems are the most commonly used.

Organotin compounds represent, with a consumption of 15,000 tonnes21 about 9.3%
of the European consumption of stabilisers. Various types of organotins, in particular
mixtures of mono- and di-organotin compounds, are used as stabilisers, mostly in
rigid packaging film, bottles, roofing, and clear rigid construction sheeting.

According to Council Directive 67/548/EEC on the classification and labelling of
dangerous substances as amended22, most lead compounds including those used in
PVC are classified as toxic to reproduction, harmful, dangerous for the environment
(ecotoxic) and presenting a danger of cumulative effects. Lead is persistent and
certain lead compounds accumulate in certain organisms.

Most cadmium compounds are classified according to Council Directive 67/548/EEC
(ecotoxic). Other cadmium
as harmful and dangerous for
compounds are classified as being harmful, toxic or very toxic. Some compounds are
also classified as carcinogens (category 2). Cadmium is persistent and certain
cadmium compounds accumulate in certain organisms.

the environment

15

16

17

18

19

20

21

22

Donnelly, J.P. (1999): Risk Assessment of PVC Stabilisers during Production and the Product Life
Cycle. Proceedings of OSPARCOM workshop
European Industry Position Paper on PVC and Stabilisers. ECVM. Document produced by the ECVM
in conjunction with ELSA and ORTEP, 1997
Eurometaux, Annual report 1999.
OSPARCOM workshop on cadmium 1997
Figures provided by he European Stabilisers Producers Association (ESPA)
Donnelly, J.P. (1999): Risk Assessment of PVC Stabilisers during Production and the Product Life
Cycle. Proceedings of OSPARCOM workshop
Donnelly, J.P. (1999): Risk Assessment of PVC Stabilisers during Production and the Product Life
Cycle. Proceedings of OSPARCOM workshop
OJ L 196, 16/08/1967, p. 1.

8

Data on the organotin compounds used as stabilisers in PVC show that dioctyl tin is
toxic to the immune system. Such immunotoxic effects have not been observed for
the other organotin compounds used as PVC stabilisers (dimethyl tin, dodecyl tin,
monobutyl tin). Dioctyltin compounds present a possible environmental risk locally
in the aquatic environment.

A distinction has to be made between the hazards and risks from chemical
substances. At present, no comprehensive risk assessments have been completed on
the use of cadmium and lead compounds as stabilisers in PVC products. Under
Council Regulation 793/93 of 23 March 1993 on the evaluation and control of the
risks of existing substances23, a risk assessment is being finalised on cadmium and
cadmium oxide. For lead, the Scientific Committee on Toxicity, Ecotoxicity, and the
Environment (CSTEE) has recently adopted an opinion regarding a draft ban on the
use of lead in products in Denmark24. The CSTEE is currently working on the issue
of risks from the use of lead in general and an opinion, building inter alia on a study
to be commissioned by the services of the Commission, should be adopted by mid-
2001 on both the environmental and human health risks of lead.

As for most heavy metals, cadmium and lead are emitted to the environment by
many sources other than their use in products, that contribute significantly more to
the dispersion of these heavy metals in the environment, e.g. industrial activities,
petrol, fertilisers and sewage sludge. Also, both heavy metals are used in numerous
products. The most important uses for lead and cadmium in terms of quantity are in
batteries and accumulators. Apart from the use in batteries, PVC stabilisers represent
one of the main applications of lead.

The main points of interest for the discussion of the potential risks from lead or
cadmium stabilisers in PVC are the following:

• Lead and cadmium stabilisers in PVC will most probably remain bound in PVC
during the use phase and thus will not contribute significantly to exposure. A
potential contamination of the environment by the use of lead or cadmium
stabilisers in PVC can take place during the production and waste phase.

• During the phases of production and of waste treatment, a number of specific
protection and prevention measures need to be taken in order to eliminate or
reduce to a minimum the exposure of workers, in accordance with the EU’s
legislation on workers health and safety.

• No exact data are available on the contribution of lead stabilisers in PVC to the
overall lead load in municipal solid waste being landfilled or incinerated. Various
calculations and estimates have led to widely varying results: 1%, 3%, 6%, 10%25

23

24

25

OJ L 84, 05/04/193, p.1
CSTEE opinion on lead – notification 98/595/DK. Opinion expressd at the 15th CSTEE plenary
meeting. Brussels, 5th of May 2000.
Bertin Technologies, The influence of PVC on quantity and hazardousness of flue gas residues from
incineration, Study for DG XI, April 2000

9

and 28%26. For cadmium it is estimated that about 10% of cadmium in waste
incinerators or landfill originate from PVC27.

• Few experimental

investigations have been carried out on the behaviour in
landfills of PVC waste containing lead and cadmium. It can be expected that lead
and cadmium compounds would stay encapsulated in rigid PVC waste. For lead in
flexible PVC, the situation is less certain. In particular, one study28 has shown a
10% release of lead stabiliser from one type of flexible PVC cable containing a
mixture of various plasticisers. The contribution of PVC to the lead content found
in landfill leachates has not been investigated.

• During the incineration of PVC and other wastes, practically all

lead and
cadmium ends up in the bottom and fly ashes of the incinerators. Due to a high
contamination with heavy metals, fly ashes and residues, which are generally
mixed, have to be disposed of in controlled landfills. Bottom ashes are either re-
used or landfilled. A dispersion of heavy metals into the environment therefore
cannot be excluded but this seems unlikely in the short term.

Given the scientific uncertainties described above, the effect of substitution of lead or
cadmium to the overall environmental emissions cannot be precisely quantified at
present. However, it is questionable whether a general substitution of these stabilisers
would have a major effect on the overall emissions of lead or cadmium to the
environment. On the other hand, according to some analyses, the long term use of
lead stabilisers would contribute to an increase of lead concentrations in the
environment29 through the waste management phase.

Due to the issues raised by the presence of hazardous substances in waste, the
Community waste management strategy30 has stated that “preventive measures might
lead to the need for EC-wide rules to limit the presence of heavy metals in products
or in the production process or ban specific substances, in order to prevent, at later
stage, the generation of hazardous waste. This might be the case where neither the
reuse nor the recovery or the safe disposal of that substance is an environmentally
acceptable solution.”

The protection of man and the environment from risks related to exposure to
cadmium has been an issue in Community policy for several years. On 25 January
1988 the Council of the European Communities adopted a Resolution31 on a
Community action programme to combat environmental pollution by cadmium. The
Council stresses that the uses of cadmium should be limited to cases where suitable
alternatives do not exist.

With regard to the use of cadmium in stabilisers for PVC, Directive 91/338/EEC
already restricts the use of cadmium as a stabiliser in a number of PVC applications.

26

27

28

29

30

31

The Behaviour of PVC in Landfill, Study for DG ENV, Argus in association with University Rostock,
1999
Bertin Technologies, cit. op.
Mersiowski et al. 1999, Behaviour of PVC in landfills, ECVM, Technical University Hamburg-Harburg
Swedish National Chemicals Inspectorate, Additives in PVC, Marking of PVC, report of a Government
Commission, 1997
COM(96)399
OJ No C 30, 4. 2. 1988, p. 1.

10

However, the use of cadmium in PVC profiles is still allowed. Sweden, Austria and
the Netherlands have banned all the uses of cadmium in stabilisers and Directive
1999/51/EC provides for a general derogation to Sweden and Austria to apply stricter
rules concerning cadmium.

No Community legislation exists on the use of lead compounds as stabilisers.
Denmark32, Sweden33, Austria34 and Germany35, have called for further restrictions,
mandatory or voluntary, on the use of lead and cadmium, in particular as stabilisers
in PVC.

Moreover, as previously mentioned, a risk assessment
is being carried out on
cadmium as well as a scientific evaluation on lead by the CSTEE. Decisions on
potential risk reduction measures should be based on all existing scientific
evaluations. They should be reviewed in the light of new scientific developments,
including the results of potential future risk assessments.

the main
Potential substitutes of lead and cadmium are already being used,
substitutes being calcium-zinc stabilisers and tin organic stabilisers. Calcium/Zinc
compounds do have a more advantageous hazard profile than lead and cadmium
compounds and are currently not classified as dangerous. Technical reasons (product
quality, standards,
testing requirements) and economic grounds (higher costs)
currently prevent the general substitution of lead stabilisers. It is expected that in the
coming years the price difference between lead stabilisers and calcium/zinc
stabilisers will decrease due to new production capacities being currently installed.
Tin stabilisers have less favourable properties with regard to the environment and
humans.

In March 2000, the PVC industry (PVC manufacturers, PVC additive producers and
PVC converters represented by their European associations (ECVM, ECPI, ESPA,
EuPC36) combined to sign a voluntary commitment with the declared objective to
“meet the challenge of sustainable development”, through adopting “an integrated
approach to deliver the concept of responsible cradle to grave management.”

The signatories represent more than 98% of PVC polymer, additives and compound
producers, and between 60 to 80% of the transformers of window frames and pipes.

The voluntary commitment addresses different impacts of PVC on the environment,
and includes a plan for the various actions envisaged (reduction of emissions at the
production stage, limitations on the use of cadmium, progressive implementation of
recycling targets), as well as financial commitments involving the creation of a fund
designed to finance relevant research projects. The main actions envisaged relate to:

32

33

34

35

36

Notification of Denmark of a draft legislation on the restriction of the use of lead in products
Swedish National Chemicals Inspectorate, Additives in PVC, Marking of PVC, report of a Government
Commission, 1997
Austrian national legislation on the ban of cadmium in PVC
Kommission Human-Biomonitoring des Deutsche Umweltbundesamt “Blei-referenz und Human-
Biomonitoring-Werte”, 1996
Report of the Bundestag Enquête Kommission “The products of industrial society; Perspectives on
sustainability management of material streams”, recommendations regarding PVC, July 1994
ECVM is the European Council of Vinyl Manufacturers; ECPI the European Council for Plasticisers
and Intermediates; ESPA the European Stabilisers Producers Association and EuPC the European
Plastics Converters.

11

• specific obligations, details of which are indicated at appropriate points in this

document, covering the period 2000-2010

• quantitative and progressive objectives for recycling certain waste streams and

phasing out cadmium

• publication of an annual report to be made available to interested parties

• verification and evaluation of the results by an independent third party, first in

2003, and later in 2008.

• revision of objectives in order to take into account
progress as well as the suggestions of interested parties.

technical and scientific

The signing and entry into force of this commitment represents an important step
which need to be assessed in function of the effectiveness criteria mentioned in the
Communication of the Commission to the Council and to the European Parliament
concerning agreements in the area of the environment (COM(96)561 final).

The success of this approach will require a constant progression in the efforts
realised in the specific areas covered by the agreement and, in particular, reduction in
the production and use of certain additives, more ambitious target quantities for
recycling,
incineration, and a fully
operational funding mechanism.

industry’s contribution to added costs of

As regards cadmium, industry has committed itself to phase out the use of cadmium
stabilisers in 2001. This commitment does not cover the imports of PVC from third
countries, which might still contain cadmium.

Concerning the use of lead, the European Stabilisers Producers Association (ESPA)
has committed itself to carry out “initial risk assessments on lead-based stabilisers
under the CEFIC and ICCA37 programmes ‘confidence in chemicals’ by 2004”.

ESPA has committed itself to produce yearly statistics showing which stabilisers are
purchased by converters. ESPA anticipates that the 120,000 tonnes of lead used in
PVC in 1999 will decrease to 80,000 tonnes in 2010 and has stated that it “will
support this trend by developing suitable alternatives”. The PVC stabiliser industry
does not at present take measures to phase out the use of lead in PVC, other than to
“continue to research and develop alternative stabilisers to the lead-based systems”.

37

CEFIC: European Chemical Industry Council
ICCA: International Council of Chemical Associations

12

Issues for consideration

The Commission considers, on the basis of the above-mentioned analysis, that the
contamination of the environment by lead and cadmium should be avoided as
much as possible. The Commission is in favour of a reduction of the use of
cadmium and lead as stabilisers in PVC products. A number of measures could be
envisaged and should be assessed in the light of their potential environmental and
economic implications.

1.

2.

3.

Legislative phase-out or other risk reduction measures for cadmium
and/or lead with the possibility of temporary derogations

Implementation of the voluntary commitment of the PVC industry on
cadmium

Development of further voluntary commitments for lead.

Question n°1:

Which set of measures should be implemented to address the issue of the
use of lead and cadmium in new PVC? According to which timeframe?

3.3.

Plasticisers

Plasticisers are necessary to manufacture flexible PVC products. In Western Europe
about one million tonnes of phthalates are produced each year, of which
approximately 900,000 tonnes are used to plasticise PVC. In 1997, 93% of the PVC
plasticisers were phthalates. The most common phthalates are: bis-2-ethylhexyl
phthalate (DEHP), diisodecyl phthalate (DIDP) and diisononyl phthalate (DINP). In
recent years the use of DEHP has decreased, while that of DIDP and DINP has
increased. The quantities of plasticisers added to the PVC polymer vary depending
on required properties. Depending on the final use, plasticiser contents vary between
15 and 60%, with typical ranges for most flexible applications around 35 to 40%.

in particular adipates,

Other plasticisers,
trimellitates, organophosphates and
epoxidised soybean oil can also be used as softeners in PVC. These plasticisers
represent only a small fraction of the use of plasticisers. Information on the impact of
these plasticisers on the environment and on human health from their use in PVC is
limited and further data would need to be acquired for a proper assessment. This
section will therefore concentrate on phthalates, the most important plasticisers in
term of quantity and the main plasticisers currently assessed in term of
environmental and health risks.

Phthalates are high production volume chemicals, five of which have been put, due
to their potential risks to human health and the environment, on the first three priority
lists for
in accordance with Regulation 793/93 on existing
substances. The risk assessments on these five substances are carried out by Member

risk assessment

13

State rapporteurs38. The risk assessments on DEHP, DIDP, DINP, DBP have been or
are expected to be completed in 2000 and in 2001 for BBP.

DEHP, DINP and DIDP have a potential for bioaccumulation. The risk assessments
under Regulation 793/93 have concluded that no concern exists for the accumulation
potential of DBP, DINP and DIDP, whereas the potential effects on the environment
are still being assessed for DEHP and BBP. Long-chain length phthalates have a low
biodegradability under normal conditions of sewage treatment and are only partly
degraded in usual leachate and sewage treatment plants, where they accumulate on
suspended solids. Certain phthalates as well as their metabolites and degradation
products can cause adverse effects on human health (in particular on liver and kidney
for DINP and on testicles for DEHP). Potential endocrine disrupting properties are
being evaluated.

All the phthalates used in large quantities in PVC applications are ubiquitous in the
environment today. Transport in the air and leaching out from certain applications
seem to be the major routes by which phthalates enter the environment. Phthalates
are found in high concentrations mostly in sediments and in sewage sludge. In
Denmark, it has been reported that the concentrations of certain phthalates can
exceed the national limit values fixed for the use of sewage sludge in agriculture.

The risks due to the use of phthalates in certain soft PVC toys and childcare articles
have been assessed by the Scientific Committee on Toxicity, Ecotoxicity and the
Environment (CSTEE). Phthalates leach out from toys and child care articles, when
sucked by small children. In its opinions, the Scientific Committee on Toxicity,
Ecotoxicity and Environment has expressed its concern about the risks resulting from
the exposure of small children to two phthalates (DINP and DEHP) used in these
products, due to the potential adverse effects on liver, kidney and testicles. The
Commission has adopted on 10 November 1999 a Proposal for a Directive and on 7
December 1999 a Decision under the emergency procedure of Directive 92/59/EC in
order to ban of the use of phthalates in certain toys and childcare articles intended to
be put in the mouth.

Without waiting for the final stage of the above mentioned risk assessment process,
three Member States have already started to draw up risk management strategies
based on the global objective to reduce the use of phthalates. The Swedish
Government has presented a bill on “Swedish environmental quality objectives”
which aims at reducing the use of the main phthalate DEHP39. The Danish
government has adopted an action plan to reduce the use of phthalates by 50% over
the next 10 years. The sustainability of flexible PVC has also been assessed by the
German Umweltbundesamt40, which recommends a phase-out of flexible PVC, for

38

39

40

are

(DEHP),

phthalate

five phthalates

: Bis(2-ethylhexyl)

The
rapporteur Sweden; Di-
’’isononyl’’phthalate (DINP), rapporteur France; Di-’’isodecyl’’phthalate (DIDP), rapporteur France;
Dibutylphthalate (DBP), rapporteur the Netherlands; Butyl Benzyl Phthalates (BBP), rapporteur
Norway
The Swedish Government states that “the use of DEHP and other plasticizers with harmful effects in
PVC for outdoor use in coated woven fabrics and coated plate and for corrosion protection in cars
should be phased out on a voluntary basis by 2001. Other uses of DEHP as a plasticizer in PVC, with
the exception of medical products and drugs, should be phased out on a voluntary basis by 2001.”
Deutsche Umweltbundesamt, Handlungsfelder und Kriterien für eine vorsorgende nachhaltige
Stoffpolitik am Beispiel PVC, 1999

14

those applications where safer alternatives are available, due to the permanent loss of
softeners, in particular phthalates, into the environment.

Issues for consideration

The use of phthalates in PVC applications raises issues, described above, which
could be addressed through a number of measures,
including legislative or
voluntary risk reduction measures. These potential measures should be assessed
in the light of their environmental and economic implications.

Question n°2:

Should specific measures be taken for the use of phthalates as plasticisers
in PVC? If so, when and through which instruments?

4.

THE WASTE MANAGEMENT OF PVC

Four studies have been commissioned by the services of the Commission in order to
assess the technical aspects of the main waste management options for PVC waste:
mechanical recycling41, chemical recycling42, incineration43 and landfilling44.

The management of PVC waste should be assessed in the context of the European
waste management policy. The Communication from the Commission on the review
of the Community strategy for waste management45 has confirmed “the hierarchy of
principles that prevention of waste shall remain the first priority,
followed by
is further stated that
recovery and finally by the safe disposal of waste”. It
“preference should be given, where environmentally sound,
to the recovery of
material over energy recovery operations. This general rule is based on the fact that
material recovery has a greater effect on waste prevention than energy recovery. It
will nevertheless be necessary to take into account the environmental, economic, and
scientific effects of either option. The evaluation of these effects could lead, in certain
cases, to preference being given to the energy recovery option.” In its Resolution46
of 24 February 1997, the Council has endorsed this hierarchy of principles.

4.1.

Current situation and future developments

Current situation

The total quantity of PVC waste is a function of PVC consumption. However, due to
lifespans, which can reach up to 50 years and more for some applications such as
pipes and profiles,
there is a “time-lag” between PVC consumption and PVC
presence in the waste stream. PVC products reached significant market share in the
1960’s. Considering lifespans of about 30 years and more, a significant increase of
PVC waste quantities is expected to start around 2010.

41

42

43

44

45

46

Prognos, Mechanical recycling of PVC wastes, Study for DG XI, January 2000
TNO, Chemical recycling of plastics waste (PVC and other resins), Study for DG III, December 1999
Bertin Technologies, The influence of PVC on quantity and hazardousness of flue gas residues from
incineration, Study for DG XI, April 2000
Argus in association with University Rotstock, cit. op.
COM(96) 399 final
97/C 76/01

15

Due to the fact that PVC is used in a wide range of applications, data on PVC waste
arisings in the EU are uncertain. The most recent and detailed data available on PVC
waste quantities are estimations carried out by industry and are based on calculations
using production quantities per year and average lifespan of products.

It is estimated that in 1999 the total annual PVC waste quantity was about 4.1 million
tonnes in the Community, which can be divided into 3.6 million tonnes of post-
consumer PVC waste and 0.5 million tonnes of pre-consumer PVC waste. Pre-
consumer wastes are generated during the production of intermediate and final PVC
products as well as during the handling and installation of PVC products. The present
composition of PVC waste is two thirds flexible PVC and one third rigid PVC.

About one million tonnes of PVC is present in the construction and demolition waste
stream. One million tonnes of PVC can be found in the municipal solid waste stream,
which comprises wastes collected from households as well as similar wastes
collected from commercial and industrial operations. About 700,000 tonnes of PVC
packaging waste are generated and about 700,000 tonnes of PVC are found in end of
life vehicles and electrical and electronic equipment.

At present the main waste management route in the Community for all types of post-
consumer waste is landfilling. This is therefore also the case for post-consumer PVC
waste. About 2.6 to 2.9 million tonnes of PVC waste are currently landfilled every
year. Mechanical recycling is applied to only a small fraction of the post-consumer
waste (about 100,000 tonnes). Approximately 600,000 tonnes of PVC are incinerated
per year in the Community.

Future developments: baseline scenario

This scenario47 describes the situation with regard to the quantities of PVC waste and
the main waste management routes expected in the years 2000, 2010 and 2020, with
the assumption that no PVC-specific measures will be taken except for those legal,
administrative and voluntary measures in force or in preparation at Community and
at national levels. It is assumed under this scenario that existing and future Directives
on landfilling, incineration, packaging, end of life vehicles and electric and electronic
waste will be implemented.

The key element in the management of post-consumer PVC waste is the expected
increase in PVC waste quantities. Predictions of future PVC waste arisings are
subject to uncertainties but it is expected that the volume of PVC waste will increase
significantly by 30% in 2010 and by 80% in 2020, in particular due to the important
increase of waste quantities from long lifespan products. Post-consumer wastes will
increase from about 3.6 million tonnes at present to about 4.7 million tonnes in 2010
and 6.2 million tonnes in 2020. PVC pre-consumer wastes will increase from 0.5 to
0.9 million tonnes.

Compared to the current situation, it is expected that the composition of PVC post-
consumer waste arisings by product group will change. The share of PVC building
waste and waste from household and commercial products will increase, whereas the

47

Prognos, cit. op.

16

contribution of packaging is expected to decrease significantly. The proportion of
flexible PVC waste will also decrease.

In the context of the baseline PVC waste scenario, changes in waste management
legislation and practices are expected to have the following effects:

• The landfill Directive will bring some important changes to waste management
mainly due to the expected increasing landfill costs. Some Member States, in
the Netherlands and Denmark have announced
particular Germany, Austria,
national policies for banning the landfilling of untreated organic wastes, including
plastics, with the exception of PVC waste for Denmark.

• Recycling is expected to increase significantly over the next decades, in particular
for those waste streams for which recycling targets will be set. Energy recovery is
also expected to increase for waste, which cannot be recycled.

How this will affect the treatment of PVC waste will be discussed in more detail in
the following sections on the main waste management options.

4.2.

Mechanical recycling

Mechanical recycling refers to recycling processes where PVC waste is treated only
mechanically, mainly through shredding, sieving, and grinding. The resulting
recyclates (in powder form) can be processed into new products. Depending on the
degree of contamination and the composition of the collected material, the quality of
the PVC recyclates can vary a lot. The quality of the recyclates determines the
degree, to which virgin material can be substituted by recyclates: “high-quality”
recyclates can be re-used in the same types of PVC applications, whereas “low-
quality” recyclates from mixed waste fractions can only be “down-cycled” into
products usually made from other material.

Recycling of post-consumer waste is still at a low level in the EU and the quantities
recycled represent less than 3% of the total48. About 100,000 tonnes are currently
recycled per year in the EU. A major part of the post-consumer PVC waste recycling
(about 70%) is down-cycling in the area of cable wastes (about 38,000 tonnes) and
packaging waste (about 19,000 tonnes).

High-quality mechanical recycling for post-consumer wastes is still in a preliminary
stage and exists only for few product groups and with low quantities (about 3.600
tonnes of rigid profiles, 5,500 tonnes of PVC pipes and 550 tonnes of flooring).

There appears to be no Member States where the recycling rate of post-consumer
waste is significantly higher than the EU average. In some countries, collection
schemes have been established, usually through voluntary approaches. However, the
recycling rate is usually below 5% and is largely based on the down-cycling of
packaging and cables.

As far as pre-consumer wastes are concerned, about 420,000 tonnes of PVC were
recycled in 1998, representing about 85% of pre-consumer PVC waste arising.

48

Prognos, cit. op.

17

Mechanical recycling of pre-consumer waste exists in all Member States and can be
considered as a profitable economic activity.

A number of life cycle assessments49 on some specific PVC products have shown
that mechanical recycling provides an environmental advantage for production
waste, cut-offs and post-consumer PVC waste, which can be separated. The
environmental advantages of the down-cycling of mixed plastics for the production
of products which substitute concrete, wood or other non-plastic applications are less
certain.

However, the presence of additives classified as hazardous, such as lead, cadmium
and PCBs, in large PVC waste streams raises specific issues during their potential
recycling. The recycling of PVC waste containing heavy metals results in a dilution
of these substances in a greater quantity of PVC, since it is necessary to add virgin
material. The heavy metals are not directly released into the environment during the
recycling process and the renewed service life. The recycling of PVC material
containing these heavy metals postpones the final disposal to a later stage. Although
it could be difficult to control the use of recycled PVC containing lead and cadmium,
for technical reasons it is unlikely that PVC waste from various applications would
be recycled together in case of high quality recycling. Due to the product-specific
additives formulations, recyclers would prefer recycling into similar applications.
Additional measures, such as restrictions of the uncontrolled sale of recyclates
containing heavy metals or its down-cycling, could be envisaged. A prohibition of
the recycling of PVC waste containing heavy metals would eliminate the mechanical
recycling of post-consumer PVC wastes from building applications - the waste
stream with the highest potential for high-quality recycling - as they virtually all
contain lead or cadmium. It should be noted that, except for Denmark, Member
States, which have banned the use of cadmium as stabilisers, allow the recycling of
PVC waste containing cadmium. The problem of PCBs in PVC cable waste has been
addressed in Directive EC/96/59 on the disposal of PCB and PCT, which provides
that cables containing more than 50 ppm of PCBs are considered as PCBs and have
therefore to be decontaminated or disposed of in accordance with the provisions
established under this Directive.

PVC can have a negative influence on the recycling of other plastics in mixed plastic
waste. When PVC is processed with other plastics, such as in the packaging waste
stream, the processing temperature is limited to the range of PVC-processing, which
is a relatively low range compared to other plastics. Due to similar densities,
polyethylene terephthalate (PET) and PVC waste are difficult to separate and the
presence of PVC puts additional costs on some PET recycling schemes such as the
PET bottles. In some cases,
the PVC industry has recognised this issue and
contributes to this additional cost.

As in the case of other materials, the recycling of PVC is also limited by the overall
recycling costs. Economic profitability is reached when the net recycling costs (i.e.
the overall costs for collection, separation and processing minus the revenues from
sale of the recyclates) are lower than the prices for alternative waste management
routes for related PVC wastes. If economic profitability cannot be reached, the
recycling of PVC waste will not take place under free market conditions, unless there

49

Prognos, cit. op.

18

are legal obligations or voluntary measures enforcing or promoting the recycling of
PVC. Collection represents the major bottleneck regarding the availability of waste
and costs.

High-quality recycling of post-consumer waste (in particular pipes, profiles, flooring)
is at present not profitable, as the net recycling costs are well above the costs for
landfilling or incineration. In addition, there are further costs for the waste owner for
separation of wastes at the construction sites.

Low-quality recycling of post-consumer PVC waste, such as for packaging waste, is
not economically profitable. Economic profitability is not likely to be reached for
other waste streams suitable for low-quality recycling, such as office supplies,
printing films. Cable insulation is the only post-consumer waste, which can be
recycled at competitive costs, due to the presence of valuable metals, such as copper.

In conclusion, the recycling of pre-consumer waste can, in principle, be profitable.
However, post-consumer PVC waste recycling is far from reaching economic
competitiveness. In addition to the establishment of recycling schemes with a broad
regional coverage, financial incentives are necessary for a separate collection of PVC
wastes. Also, PVC is often present as a component in composite materials, or mixed
in contaminated waste streams, which require specific collection and sorting
operations. The price of virgin material, which is highly volatile (between 0.5 and 0.8
€
/kg), has a large influence on the profitability of recycling. In addition, the prices
for landfilling and incineration are low. Nevertheless, in the coming years, it can be
expected that
in
particular due to the increasing costs for landfilling and incineration.

the economic conditions for recycling are likely to improve,

Future developments and policy orientations

In the baseline scenario about 9% of the total PVC waste could be mechanically
recycled in 2010 and 2020, representing about 400,000 tonnes of PVC waste in 2010
and 550,000 tonnes in 202050. The recycling rates vary according to the specific
waste streams considered.

• For high quality recycling, the following recycling rates could be reached for
construction and demolition PVC wastes: about 25% for pipes, about 40% for
window profiles and about 12% for flooring.

• For low-quality recycling, the recycling rates would be about 65% for cables
present in the construction and demolition waste stream, about 30% for waste
from electronic and electronic equipment and about 20% for packaging.

• Other waste streams such as household and commercial wastes are not likely to be

recycled according to the assumptions made in this scenario.

Compared to this baseline scenario, maximum recycling potentials have been
estimated51, which represent the PVC quantities, which can be recycled, taking into
account the technical and economic limits of PVC recycling. According to this
scenario, the potential for post-consumer waste is about 800,000 tonnes in 2010 and

50

51

Prognos, op. cit.
Prognos, op. cit.

19

1.2 millions tonnes in 2020, representing a recycling rate of about 18%. This means
that the mechanical recycling of PVC waste could contribute only to the management
of about one fifth of PVC post-consumer waste. Other waste management routes will
therefore remain important.

In its commitment of March 2000,
the PVC industry has made quantified
commitments regarding the mechanical recycling of pipes, fittings and window
frames. For pipes, the commitment is “to recycle at least 50% of the collected
available quantity of pipes and fitting waste by 2005”. For window profiles, the
commitment is “to recycle at least 50% of the collectable available quantity of
window profiles waste by 2005”. These targets are not based on waste generated but
on waste collected.

According to the PVC industry,
in 2005 the annually recycled quantities are
estimated as follows: 15,000 tonnes for pipes and 15,000 tonnes for window profiles.
However, the following large PVC waste streams, which could be used for high
quality recycling, are not covered by the commitment: rigid profiles other than
window profiles (about 240,000 tonnes in 2005), flooring calandered (about 240,000
tonnes in 2005) and flexible profiles and hoses (about 120,000 tonnes in 2005).
Nonetheless, in its commitment, the PVC industry has stated that in the case of other
potential applications such as PVC cables, flooring and roofing membranes, “more
work
technologies and reuse
applications”. In addition, the industry has committed itself to supporting these
developments including the achievement of higher mechanical recycling targets “as
soon as possible.”

is needed in developing suitable

logistics,

20

Issues for consideration:

The Commission considers, on the basis of the above-mentioned analysis and
given the present low recycling rate, that recycling of PVC should be increased.
This could be done through a range of measures, which could be used separately
or in combination. Their potential environmental and economic implications
should be assessed. These potential measures include:

1.

2.

3.

4.

5.

6.

Mandatory collection and recycling targets for some relevant PVC waste
streams

Voluntary commitment of the industry to improve and finance, totally or
partially, the collection and the recycling of some relevant PVC waste
streams

Recommendations to Member States with the objective of establishing and
developing separate collection of PVC waste and other demolition waste

Development of appropriate standards that allow the use of recycled PVC
materials

Marking of plastic products as a useful tool to facilitate the separation of
PVC waste from the general waste stream and development of other
methods for plastic identification and sorting

Development of innovative recycling processes for certain post-consumer
PVC waste.

Question n°3:

Which set of measures would be the most effective to reach the objective of
an increase of PVC recycling?

The recycling of PVC waste containing heavy metals raises specific issues due to
the potential dilution of heavy metals into new and possibly wider range of
products. Some potential measures could be envisaged to address these issues.
These measures should be assessed in the light of their potential environmental
and economic implications. They include:

1.

2.

Legislative instruments to restrict the mechanical recycling of PVC waste
containing lead and cadmium

Specific conditions for this recycling, such as recycling in the same type of
application, the control of the placing on the market of recyclates, the
marking of the recycled products and the control of the use of heavy
metals

3.

No specific conditions for this recycling.

Question n°4:

Should specific measures be attached to the mechanical recycling of PVC
waste containing lead and cadmium? If so, which ones?

21

4.3.

Chemical recycling

Chemical recycling denotes a number of processes, by which the polymer molecules
that constitute plastic materials are broken up into smaller molecules. These can
either be monomers that can be used directly to produce new polymers or other
substances that can be used elsewhere as starting materials in processes of the basic
chemical industry.

In the case of PVC, in addition to the breaking up of the backbone of the polymer
molecules, the chlorine attached to the chains is set free in the form of hydrogen
chloride (HCl). Depending on process technology, HCl can be re-used after
purification or has to be neutralised to form various products that either can be used
or have to be disposed of.

In practice, during the last 5 years, there have been only a limited number of
initiatives that have resulted in the construction of industrial plants, or may lead to
the realisation of such plants in the near future. Chemical recycling processes can be
categorised according to their capacity to handle waste with high or low chlorine
content, 4 to 5% being the maximum PVC content
that can be handled by
low chlorine content. Of the three operational purpose-built
technologies for
chemical recycling plants for waste with low chlorine content, two have been shut
down due to economic and supply reasons. For PVC-rich waste there is currently one
incineration-based technology with HCl recovery operational, two pilots will become
operational in the coming years.

According to several
life cycle assessments (LCA), some chemical recycling
processes would score considerably better with regards to energy use and global
warming than municipal solid waste incineration and landfilling. In addition, in some
processes chlorine is recovered, thus avoiding new production through energy-
intensive chloralkali-electrolysis. The available LCAs did not allow a clear
preference to be made for one of the chemical recycling technologies analysed.
Direct mechanical recycling of PVC-rich waste is preferable in environmental terms,
particularly if it concerns recycling to high-quality products, and does not involve
extensive sorting and pre-treatment52

Together with the organic parts in PVC, plasticisers are transformed into feedstock
material as well. Stabilisers containing heavy metals mostly end up in solid residues
that will most probably have to be landfilled. For most of the dedicated chemical
recycling technologies, emissions of problematic substances other than solid residues
are low53. No firm conclusions can be drawn with regard to the formation of dioxins.
As a general rule, reducing conditions and high temperatures promote the breakdown
and prevent the formation of dioxines, which is the case in some processes where the
operating conditions avoid the formation of dioxins.

It seems that chemical recycling of PVC-rich waste is unattractive in economic terms
in those situations where mechanical recycling has proven already to be technically
feasible, with the possible exception of flooring. This would imply that chemical
recycling plants for PVC-rich waste would have to concentrate on those flows for

52

53

TNO, Chemical recycling of plastics waste (PVC and other resins), Study for DG III, December 1999
TNO, op.cit.

22

which mechanical recycling is not feasible, e.g. for types of waste that cannot be
mechanically recycled as they would require additional separation steps, contain too
many problematic impurities, or because of other restrictions linked to environmental
concerns.

Chemical recycling has to compete with other waste management practices in the
EU, mainly based on landfill and incineration. Landfill and incineration have the
lowest gate fees. Purpose-built chemical recycling plants will also face an important
competition from blast furnace operations and cement kilns, which could absorb a
large quantity of mixed plastics waste with limited PVC content.

When looking at the various waste streams, it appears that in the current situation for
categories like agricultural waste, industrial waste and non-packaging household
waste, chemical recycling, although technically feasible, will have problems to
compete in the absence of legal or other steering instruments. As for automotive and
electrical and electronic waste, the PVC content in the mixed plastics waste seem to
be too high to make them suitable for most chemical recycling options for mixed
plastics waste with low chlorine content, but
too low for economically viable
separation and subsequent treatment in plants for PVC-rich waste.

Overall, it can be concluded that the successful operation of dedicated chemical
recycling plants is mainly dependent on the economic aspects and in present
circumstances there are important question marks over
the viability of such
operations.

Future developments and policy orientations

Chemical recycling has a potential mostly for those wastes for which mechanical
recycling is not an option, and when legal or other instruments are effective in
steering the waste away from the most cost-effective competitors (such as cement
kilns, municipal solid waste incinerators and landfill).

For 2010, the total PVC waste quantities, which could be chemically recycled in the
baseline scenario, are about 80,000 tonnes as a fraction in mixed plastics waste with
low chlorine content (mostly from packaging) and about 160.000 tonnes in mixed
plastics fractions with higher PVC content, mostly from automotive and electric and
electronic waste.

Industry committed to invest 3 million
by 2001 in a pilot plant, with the objective
to recover the chlorine and hydrocarbons content of PVC coated fabrics. The
outcome of this pilot will be known by mid 2002, when the decision to build a
commercial plant will be made.

€

23

Issues for consideration:

The Commission notes with interest the efforts described above to develop further
chemical recycling technologies. In this context, potential measures could be
envisaged in order
these developments. Their potential
environmental and economic implications should be assessed. Such measures
include:

to encourage

1.

2.

3.

Further voluntary initiatives from the PVC industry

Recommendations for targets for chemical recycling for those waste
streams where mechanical recycling is not possible

Setting of mandatory targets for chemical recycling.

Question n°5:

Which set of measures would be most appropriate for chemical

recycling

of PVC waste?

4.4.

Other recycling and recovery technologies including co-incineration

A newly developed dissolution-precipitation process is based on physical principles
without destruction of the polymer molecules to feedstock compounds. The process
was developed specifically for composite materials containing PVC and other
components. PVC is separated from the components that make up the composite
through selective dissolution, and then the entire PVC compound is regenerated
through precipitation. PVC and the other components can then be re-used.

Currently, an experimental installation is operational and a pilot plant is planned to
be operational in 2001. The technology works in a closed circuit system, where the
solvent is recycled.

The process deals with selectively collected PVC products. The quality has to be
about the same as for mechanical recycling, which means that the costs of making
the material available are comparable. The developers of this process expect that the
technology could deal with rather complicated formulations, such as tarpaulins,
cables, pharmaceutical blister packs, floor coatings, car dashboards, and could
compete financially with some of the other recycling options.

Mixed plastic waste is used by one German steel producer as a reducing agent in
blast furnaces in the production of raw iron. Mixed plastic waste is also used in
cement kilns as a substitute to coal, oil or gas for the generation of heat.

The evaluation of the environmental performance of the use of mixed plastic waste in
blast furnaces and cement kilns is somewhat controversial. According to some life
cycle analyses, blast furnaces and cement kilns score better with regards to energy
used and global warming than municipal solid waste incineration. With regards to the
potential contribution of PVC to the emissions of dioxins, it is rather difficult to draw
firm conclusions and further research would be necessary.

24

Blast furnaces and cement kilns can treat mixed plastic waste without the need for
high capital investment, thus offering low gate fees. The use of mixed plastic waste
in cement kilns and blast furnaces represents serious competition for other waste
management installations. On the other hand, the use of mixed plastic waste in
cement kilns and blast furnaces is restricted by its content in chlorine, as chlorine can
have negative effects on the quality of the produced cement or iron and the potential
corrosion of the equipment due to the formation of HCl. A tolerance of some 2-3%
or less is possible54. Theoretically, co-combustion in cement kilns of mixed plastic
waste with low PVC content could, however, become important in the future.

4.5.

Incineration

PVC waste, if incinerated, is mainly treated in municipal waste incinerators. PVC
waste is also present in hospital waste incinerators since PVC applications are used
in hospitals. Approximately 600,000 tonnes of PVC are incinerated per year in the
Community. PVC represents about 10% of the plastic fraction incinerated and about
0.7% of the total quantity of waste incinerated55.

PVC waste contributes between 38% and 66% of the chlorine content in waste
streams being incinerated. The other main sources of chlorine are putrescibles (about
17%) and paper (10%). On average it can be estimated that about 50% of the
chlorine input into the incinerators are due to the presence of PVC.

Upon incineration, PVC waste generates hydrochloric acid (HCl) in the flue gas,
which needs to be neutralised except when a special technology is employed where
HCl is reused. At the moment, this specific technology is used only in 5 plants in
Germany and 3 plants are in construction. All acid gases generated during the
incineration of municipal solid waste (in addition to HCl mainly sulphur oxides)
have to be neutralised prior to emission of the remaining gas to the atmosphere.
Community legislation56 already requires emission limit values for hydrochloric acid.
These limits are currently being revised into more stringent limits57.

In order to reach these emission limit values for HCl, neutralisation agents, in
particular lime, are injected in order to neutralise the acidic components of the flue
gas. The four main neutralisation processes are the dry, semi-dry, semi-wet wet and
wet processes, which are presented in more details in annex 1.

An assessment58 of the quantities of flue gas cleaning residues resulting from the
incineration of PVC waste concluded that the incineration of 1kg of PVC generates
on average59 between 1 and 1.4 kg of residues for the dry process with lime, semi-dry

54

55

56

57

58

59

Or some 1-1.5% chlorine. Values may vary per installation, and legal demands may vary per country.
Bertin Technologies, cit. op.
Directive 89/369/EEC on the prevention of air pollution from new municipal waste incineration plants
requires emission limit values for hydrochloric acid between 50 and 250 mg/Nm3 depending on the
capacity of the incineration plant.
The Proposal for a Directive on the incineration of waste [COM(1998) 558 final] as well as the
Common Position on this Proposal [98/289 COD of 25 November 1999] foresees a strict emission limit
value for HCl of 10 mg/Nm3, which will become in 2005 the emission limit value for existing and new
incinerators in the Community.
Bertin Technologies, cit. op.
The average figure apply to a PVC material mix with 45% chlorine, i.e. composed of 70% rigid PVC
(containing 53% chlorine) and 30% flexible PVC (containing 25% chlorine)

25

and semi-wet wet processes. With the use of sodium hydrogen-carbonate as
neutralisation agents in semi-dry process, 1 kg of PVC generates about 0.8 kg of
residues. In case of wet processes, between 0.4 and 0.9 kg of liquid effluent is
generated. There is an important difference between the amounts of neutralisation
agent required and residues produced between soft and rigid PVC. Flexible PVC
contains less chlorine than rigid PVC. The amounts of neutralisation agents required
and of residues generated are therefore lower for flexible PVC than for rigid PVC (1
kg of soft PVC60 generates between 0.5 and 0.78 kg of residues). More details can be
found in the following table.

Table 3: Estimated quantities of residues generated by the incineration of
1 kg of PVC waste61

Neutralisation Agent
Min
Max
Average
Min
Max

Cl kg per
kg of PVC
Residues (kg)

(per kg PVC) Average
Liquid effluent (dry
material) (kg per kg PVC)

DRY

SEMI-DRY

WET

Lime BICAR

Lime

Lime

SEMI WET –
WET
Lime

0.25
0.53
0.45

0,78
1.65
1,40

0

0,46
0.97
0,82

0

0,70
1.48
1,26

0

0
0
0

0.42 to 0.88

0.54
1.15
1

0

The flue gas cleaning residues are classified as hazardous waste62. The residues are
generated separately (in particular in semi-wet and wet systems) or mixed with fly
ash. The residues contain the neutralisation salts, the excess neutralisation agent as
well as pollutants such as heavy metals and dioxins that were not destructed.
Landfilling of the residues is, with some exceptions, the only option used within the
Member States.

Several processes have been devised to recover calcium chloride and sodium
chloride from the residues of the dry and semidry processes, but few of them are
currently used commercially. Except in some specific cases, it is uncertain whether
such technologies can be commonly used in order to recover a substantial quantity of
residues. These technologies would be “end of the pipe” solutions, less preferable
than a preventive measure aimed at reducing at source the quantity of residues
generated.

60

61

62

For these calculations, soft PVC contain 0.25% of chlorine
Bertin Technologies, The influence of PVC on quantity and hazardousness of flue gas residues from
incineration, Study for DG XI, April 2000
According to Council Decision 94/904/EC establishing a list of hazardous waste, OJ L 356 , 31/12/1994
p.14-22, all solid waste from gas treatment are classified as hazardous (code 190107).

26

PVC at current levels in the municipal solid waste stream has the following effects
on the flue gas cleaning residues in comparison to incineration of municipal solid
waste without PVC63:

• PVC incineration contributes to an increase of the quantity of flue gas cleaning
residues (about 37% for the dry systems, 34% for semi dry systems and 42% for
semi wet-wet 64).

• PVC incineration contributes to an increase of the content of leachable salts in the
residues by a factor of two. These are primarily chlorides of calcium, sodium, and
potassium.

• The incineration of PVC increases the amount of leachates from the residues put
into landfill (about 19% for dry systems, 18% for semi dry systems, 15% for the
semi wet-wet systems and 4% for wet systems). The leachates need to be treated
prior to any discharge.

• There is a theoretical possibility that the leaching of, for example cadmium, may
increase due to increased chloride complexation caused by PVC incineration but
data would be needed to substantiate this.

• In the current temperature range of combustion steps for municipal solid waste
incineration, the higher chlorine content has no significant effects on the transfer
of heavy metals and trace elements from bottom ash to gas treatment residues.

The potential influence of the incineration of PVC waste on the emissions of dioxins
has been at the centre of a major scientific debate since PVC is currently the largest
contributor of chlorine into incinerators. The contribution of incinerators to the total
emissions of dioxins in the Community was about 40% between 1993 and 199565.

It has been suggested that the reduction of the chlorine content in the waste can
contribute to the reduction of dioxin formation, even though the actual mechanism is
not fully understood. The influence on the reduction is also expected to be a second
or third order relationship66. It is most likely that the main incineration parameters,
such as the temperature and the oxygen concentration, have a major influence on the
dioxin formation.

Whilst at the current levels of chlorine in municipal waste, there does not seem to be
a direct quantitative relationship between chlorine content and dioxin formation, it is
possible that an increase of chlorine content in the waste stream above a certain
threshold could contribute to an increase of the dioxin formation in incinerators. The
threshold of 1% of chlorine has been suggested67 but uncertainties remain on the

63

64

65

66

67

Bertin Technologies, op. cit.
The scenario considered is based on the incineration of 1 million tonnes of waste with and without
PVC, respectively, and the landfilling of the resulting residues.
Bertin Technologies, op. cit.
Identification of relevant
Nordrhein-Westfalen, Essen, 1997
Danish Environmental Protection Agency, Environmental aspects of PVC, 1996
Wikstrom, 1996, influence of level and form of chlorine on the formation of chlorinated dioxins,
dibenzofurans and benzenes during the combustion of an artificial fuel inn a laboratory reactor.

industrial sources of dioxins and furans in Europe, Landseumweltamt

27

level of this threshold68. Further assessment should be carried out in order to assess
the threshold above which the chlorine content would influence the formation of
dioxins. This threshold could be exceeded due to increasing quantities of waste
containing chlorine.

At present, not all incinerators in the Community are already operating according to
state-of-the-art air-emission standards for dioxins. The Proposal for a Directive on
the incineration of waste69 foresees an emission limit value of 0,1 ng/m³. This shall
decrease the emissions of dioxins from incinerators.

The potential
link between the incineration of PVC and the corrosion of the
equipment of incinerators has also been debated. Some operators claim that the steam
pressure and consequently the energy efficiency could be higher with a lower
chlorine presence in the waste stream. The absence of PVC could therefore enable a
higher efficiency of the energy recovery system. This question needs further
research. It should be noted that the incineration with energy recovery of PVC waste
generates higher energy than the incineration of general municipal solid waste since
the calorific value of PVC waste is higher70.

PVC waste incineration increases the operating costs of the incinerators due to the
use of neutralisation agents to neutralise the acid flue gas and the additional costs for
the waste management of the resulting residues. The total additional financial costs
related to the incineration of PVC vary depending on the Member State,
the
neutralisation processes and the waste management of the residues. It is estimated
that the additional costs of incinerating PVC compared to municipal solid waste is
per tonne for dry
from about 20
systems71. Differences depend upon the technology used and the type of PVC
incinerated (flexible or rigid). More details on these costs can be found in annex 2.
These additional costs are at present not borne specifically by new PVC products or
by PVC waste, but are included in the overall incineration cost of waste.

per tonne for wet systems to more than 300

€

€

A study72 has been commissioned to assess the economic implications of diverting
PVC waste away from incineration. The report analyses three scenarios in
comparison to the baseline scenario (see annex 3 for details). In the first and the
second scenarios, recycling rates increase to 15% and 22% respectively in 2020, with
a proportionate decrease in the amount of PVC sent to incineration and landfill. With

68

69

70

71

72

Danish Environmental Protection Agency, Dioxins emissions from waste incineration, Environmental
Project 117, 1989
Danish Environmental Protection Agency, The effects of chlorine content on the formation of dioxin,
Project 118, 1989
Danish Environmental Protection Agency, Dioxins – sources, levels and exposures in Denmark,
Working report N°50/1997
[COM(1998) 558 final]
The average caloric value for flexible PVC is about 16 GJ/tonne, about 20 GJ/tonne for rigid PVC and
about 10 GJ/tonne for municipal solid waste.
Bertin Technologies, op. cit.
AEA Technology, Economic evaluation of PVC waste management, a report produced for the European
Commission Environment Directorate-General, June 2000. The study encompasses EU Member States
+ 6 Candidate countries. The reported figures relate to the average between the “high” and the “low”
incineration scenarios. These scenarios are based on the assumption that landfilling of PVC waste
would be significantly reduced in some countries such as Sweden, Austria, Germany and the
Netherlands. The difference relates to the degree of reduction achieved. Values shown refer to a 4%
discount rate.

28

regard to incineration this means a cumulative diversion of about 1,700 ktonnes for
scenario 1 (mainly construction waste) and 3,800 ktonnes for scenario 2 in the time
period 2000 to 2020. In the third scenario recycling rates are unchanged against the
baseline scenario, but the incineration rate is estimated as 28% in 2020 instead of
45% as forecasted in the baseline scenario as a result of the diversion of construction
waste to landfill. This corresponds to the diversion of about 10,300 ktonnes in the
time period 2000 to 2020.

The financial costs considered for scenarios 1 and 2 include the avoided cost of
incineration (including “specific costs”73) and the incurred net cost of the recycling
process which depends on the waste stream diverted. The specific costs of
incineration vary considerably depending upon the types of flue gas cleaning
systems. Calculations in the report have been carried out for an “average” system
distribution consisting of 25% semi dry-systems, 25% wet systems and 50% semi-
wet wet systems. The results show that except in the case of rigid construction
products (pipes, windows, cable trays and other rigid profiles) and cables, diversion
of PVC waste from incineration to recycling results in a net increase in costs. The
€
costs per tonne diverted have been estimated to be about 50
/tonne for scenario 1
and about 190
/tonne for scenario 2. Scenario 3 results in a net saving of about 90
€
/tonne. These latter savings are mainly due to the lower cost of landfill and to the
assumption that segregation of construction waste is generally carried out on site at
the expense of the waste generator. Diversion of other waste streams to landfill (e.g.
household and commercial waste) would result in much higher costs.

€

The main environmental burdens including the related human health impacts of the
three scenarios have been assessed. To the extent possible, and therefore with a bias
towards impacts of air pollution, the external costs associated to each scenario have
been evaluated. The calculations for all the scenarios show environmental benefits.
Considering what is regarded in the study as being the “best” estimate for each of the
burdens evaluated, benefits have been estimated for the three scenarios to be
per tonne of waste diverted for the period 2000-
respectively about 190, 140 and 50
2020. The major contribution to these results comes firstly from the avoided
emissions from the manufacture of virgin PVC (in the case of high quality recycling)
and secondly from the avoided emissions from incineration (including indirect
emissions associated with the manufacture of neutralisation agents).

€

It can be seen from the comparison between the financial and the environmental
analyses based on the best estimate that scenario 1 and scenario 3 show an overall
benefit, as the costs per tonne diverted are lower than the benefits. The contrary is
true for scenario 2, where the environmental benefit (although higher than in scenario
1 and 3) is nevertheless exceeded by the estimated cost.

A number of assumptions have been made to carry out
these calculations. In
particular, concerning the financial aspects, the cost elements were necessarily based
on very few experiences of existing PVC post-consumer waste recycling schemes,
which are still at a preliminary stage. These uncertainties are higher for scenario 2.

73

Incineration of PVC with municipal solid waste (MSW) incurs additional operating costs for the
incinerator in terms of reagents to abate acid gas emissions and for the treatement and disposal of
residues, although these are partly offset by increased energy sales due to the higher calorific value of
PVC compared to MSW.

29

As the price of recyclates is closely linked to the price of virgin PVC, increasing
prices of the latter would lead to lower overall costs.

As indicated,
the environmental analysis is biased towards the impacts of air
pollution. However, it is likely that most of the externalities omitted (e.g. residues
disposal) would increase the benefits of the diversion of PVC from incineration. The
main exception relates to phthalate plasticisers. Landfilled flexible PVC would form
a reservoir of these chemicals that could slowly leach out over time, whilst
incineration presents the advantage of destroying them. Incineration also allows the
recovery of the calorific value of phthalates. This factor has been included in the
environmental analysis.

Future developments and policy orientations

In the baseline scenario, the incineration of PVC waste would increase to about 2.5
millions tonnes in 2020 compared to about 600,000 tonnes at present. The number
and capacity of incinerators employing wet, semi-wet wet and semi-dry flue gas
neutralisation technologies will increase at the expense of those employing dry
technologies.

Issues for consideration:

The Commission considers, on the basis of the above-mentioned analysis, that the
incineration of PVC waste raises a number of issues. A range of measures could
be envisaged to address these issues and should be assessed in the light of their
potential environmental and economic implications. Such measures include:

1.

2.

3.

4.

5.

Diversion of PVC waste, mandatory or not, as far as economically
feasible, from incineration to preferably recycling or landfilling. This
would require the introduction of collection schemes to ensure separate
collection of PVC to be diverted

Similar diversion only for rigid PVC

Meeting the additional costs related to the incineration of (totally or
partially), e.g. through internalisation of these costs in the price of new
PVC products or direct financial contribution to operators of incineration
plants

Encouragement of the conversion of the flue gas cleaning technologies
that reduce the amounts of residues generated or allow the recycling of
HCl instead of its neutralisation

Further research on the potential relation between PVC incineration and
dioxin formation should be carried out.

Question n°6:

Which set of measures would be most effective to address the issues
linked to the incineration of PVC waste?

30

4.6.

Landfill

Landfilling is the most common waste management route for PVC waste. Exact
figures on the landfilling of PVC waste are not known and there are large differences
between various estimations ranging up to 2.9 million tonnes of PVC waste being
landfilled every year. It can be estimated that several tens of million tonnes of PVC
waste have already been landfilled during the past 30 years.

Member States will have to bring into force the provisions of Directive 1999/31/EC
on the landfilling of waste in 2001. The Directive requires that landfill installations
comply with a number of technical standards regarding the protection of soil and
water including leachate collection, bottom sealing and gas emission control.

All materials in landfill including PVC are subject to different reactive conditions,
which are determined by the parameters such as temperature, moisture, presence of
oxygen, activity of micro-organisms and the interactions between parameters at
different stages of the ageing process of landfills. Four main phases can be
distinguished: short
initial aerobic phase, anaerobic acidogenic phase (variable
duration, longer than aerobic phase), anaerobic methanogenic phase (up to several
centuries), final aerobic phase.

Investigations74 have been carried out on both rigid and soft PVC samples mainly
through laboratory equipment studies, examination of the effects of a biological
treatment, and of microbiogical tests.

The PVC polymer is generally regarded as being resistant under soil-buried and
landfill conditions75. However, an attack on the PVC polymer of a thin packaging
foil has been detected76. This remains an isolated result and the attack was observed
under aerobic conditions and at 80°C, conditions which, if they occur in landfills, are
transient.

from flexible PVC are widely
Losses of plasticisers, especially phthalates,
recognised in the literature. Results from studies on the degradability of phthalates
under landfill conditions show that degradation of phthalates occurs, but may not be
complete depending on conditions and type of phthalate. Both, phthalates and their
degradation substances can be detected in landfill leachates. In addition, long-chain
phthalates, such as DEHPs, are only partly degraded in usual leachate and sewage
treatment plants and accumulate on suspended solids. Losses of phthalates could also
contribute to gaseous emissions from landfills. As for other emissions from landfill,
emissions resulting from the presence of PVC in landfills can last longer than the
guarantee of the technical barrier and there is no evidence that
the release of
phthalates will come to a standstill after a given period of time.

Stabilisers are encapsulated in the matrix of rigid PVC waste. Hence, migration is
expected to be low and would affect the surface of the PVC but not the bulk of the
material. Concerning stabilisers in flexible PVC waste, a study77 into the long-term

74

75

76

77

Argus in association with University Rotstock, op. cit.
Mersiowski et al. 1999, Behaviour of PVC in landfills, ECVM, Technical University Hamburg-Harburg
Argus in association with University Rotstock, op. cit.
Mersiowski et al., op. cit.

31

behaviour of PVC waste under landfill condition showed a release of lead stabiliser
from one specific PVC cable containing a combination of several plasticisers.

PVC products disposed of in landfills will certainly contribute to the formation of
dioxins and furans during accidental landfill fires, but the quantitative contribution
cannot currently be estimated due to the inherent difficulties in obtaining the
necessary data.

In order to further assess and quantify the environmental impacts of the landfilling of
PVC, further research would be necessary to study the potential degradation of PVC
polymer, the release of stabilisers and plasticisers, as well as the environmental
contribution of phthalates to the leachates and gaseous emissions from landfills.

The costs for landfilling PVC waste in Member States are those for landfilling
municipal solid waste and show a wide range of tariffs78. The prices or tariffs for
landfills are influenced by a number of factors such as the standard of the landfill, the
competition between different disposal routes, the type and nature of waste being
accepted. Generally, no influence on prices or tariffs could be related or is expected
due to the presence of PVC in municipal solid waste being landfilled.

Future developments and policy orientations

In the baseline scenario, it is expected that the quantities of PVC waste landfilled
would remain constant at about 2.8 millions tonnes in 2020.

Issues for consideration:

the
The Commission considers, on the basis of the previous analysis,
landfilling of flexible PVC waste raises some issues. A range of measures could
be envisaged to address these issues. Environmental and economic implications
of these measures should be considered. Such measures include:

that

1.

2.

Disposal of flexible PVC waste in controlled landfill sites with high
emission standards as foreseen in the landfill Directive

Further research on the leaching or emissions of additives.

Question n°7:

Are specific measures concerning the landfilling of PVC waste necessary?
If so, which ones?

78

At present, the costs for landfilling municipal solid waste range from 8
per tonne in Germany. The cost for landfilling mixed waste, such as unsorted construction and
demolition waste containing organic components, is usually higher than for landfilling of inert waste.
An average price of about 50

per tonne in Spain up to 200

per tonne is usual.

€

€

€

32

5.

OTHER HORIZONTAL ASPECTS ON PVC

The analysis in this document focuses on two main aspects : the use of additives in
PVC and the management of PVC waste. In addition, more general and horizontal
aspects arise in the context of a broad consultation on PVC.

Regarding the type of instruments to implement a horizontal Community strategy on
PVC, a range of measures, mandatory and voluntary, is available:

• Voluntary approaches,

including the implementation of existing voluntary
commitments, at national and Community levels, as well as the development of
new voluntary approaches. As mentioned previously, the European PVC industry
has signed a voluntary commitment on the sustainable development of PVC. And
while this can be seen as a first step there is still work to be done to ensure an
effective participation by industry in achieving Community goals in this area. It
should be underlined that the services of the Commission are currently preparing a
Proposal for a framework Regulation concerning Community environmental
agreements to be adopted by Council and Parliament.

• Legislative measures, such as a Proposal for a Directive on PVC, could be
proposed in order to address issues related to management of PVC waste and
other legislative measures to deal with the use of additives on the basis of all
existing scientific evaluation,
risk assessments.
Recommendations could also be adopted to develop the implementation of a
Community strategy.

including the results of

• A mix of instruments could be proposed, integrating voluntary commitments,
recommendations and regulations including the adaptation of existing legislation.
Such a set of instruments would be in line with an approach, which aims at
combining voluntary and binding instruments.

Apart from an approach based on PVC waste management and additives,
the
question of a potential substitution policy for certain PVC applications has been
raised in the context of promoting more sustainable products as part of an Integrated
Product Policy. Such a substitution policy could be considered for specific
applications, which can not be separated from the general waste stream and therefore
are difficult to recycle such as in packaging, motor vehicles, electric and electronic
equipment. A potential substitution policy would need to be underpinned by a
comprehensive and objective assessment of the main environmental impacts both of
PVC and of potential substitutes during their whole life cycle. The approach outlined
in this document focuses on dealing with the environmental issues of PVC mainly
through policies on additives and waste management.

33

Issues for consideration:

A number of issues regarding the environmental impacts of PVC have been
identified, including the question of a horizontal approach and of appropriate
instruments to address these issues. The Commission sees merit in developing a
horizontal strategy on PVC. A number of instruments are available to implement
such an approach. Environmental and economic implications, as well as the
compatibility with the international obligations of the Community should be
assessed.

Question 8:

Which are the appropriate instruments for developing a horizontal
strategy on PVC? Should a PVC substitution policy for some specific
applications be envisaged? If so, how?

6.

CONCLUSION

A number of concerns regarding the impact of PVC on the environment, including
related human health issues, have been identified and explained in this document.
These are mostly related to the use of certain additives and to the management of
PVC waste. In the light of the analysis, a number of options have been identified,
which could ensure an effective approach on waste management and additives, to be
based on an assessment of the environmental and economic implications, with a view
to reducing the impact on human health and the environment of PVC throughout its
life cycle.

A public consultation on PVC is proposed on the basis of these options. The
Commission hereby invites all interested parties to discuss and comment on this
document. A public hearing will be organised in October 2000.

Comments may be sent directly to the Commission at the latest on 30 November
2000. Submissions should be sent to Mr Krämer, Head of the waste management unit
(DG ENV) and Mr Schulte Braucks, Head of the chemicals unit (DG ENTR), 200
rue de la Loi / Wetstraat 200, B-1049 Bruxelles/Brussel, Belgium. Comments may
alternatively be sent by e-mail to the following address: ENV-PVC@cec.eu.int. The
various language versions of the Green Paper, the studies commissioned by the
Commission as well as the comments on the Green Paper can be found at the
following internet address: http://europa.eu.int/comm/environment/pvc/index.htm.

On the basis of the analyses developed in this document and the outcome of this
consultation process,
the beginning of 2001 a
Communication setting out
comprehensive Community strategy on the
environmental issues of PVC.

the Commission will present at

a

34

Flue gas
cleaning
processes

Dry process

ANNEX 1

Description of the various flue gas cleaning processes

Main characteristics

The neutralisation process consists of the injection of solid neutralisation agents. The most
common neutralisation agent is lime (Ca(OH)2). Other agents are also used, in particular
sodium hydrogen-carbonate (Bicar, NaHCO3) or spongiacal hydrated lime.

A chemical reaction transforms the acidic components of the flue gas into salts. The
resulting residues of the neutralisation process are solid residues mainly composed of
neutralisation salt: calcium chloride (CaCl2), sodium chloride (NaCl), sulphates (CaSO4,
Na2SO4), excess of the neutralisation agents and heavy metals in various chemical forms.
These residues are classified as hazardous waste.

The dry process with classical lime is not likely to be able to comply with the strict
emission limit value of 10 mg/Nm3. The dry processes using specific neutralisation agents
such as spongiacal hydrated lime and Bicar can comply with this limit.

Semi-dry
process

The neutralisation process consists of the injection of a solution or a suspension of the
neutralisation agent (lime) in water. The resulting reaction products are solid residues.
They are composed of calcium chloride, sulphates and heavy metals, as well as unreacted
lime added in excess. The residues are classified as hazardous waste.

Wet process

In this process, two successive scrubbers are operating. In the first (acid scrubber), most of
the HCl is absorbed in water. The remaining HCl and SOx are absorbed and neutralised in
the second scrubber (neutral scrubber), which is generally fed with a soda (NaOH)
solution.

The resulting liquid effluents need to be treated prior to release into the environment. In
the water treatment unit, heavy metals and sulphates are precipitated by the addition of
lime. The precipitated heavy metals are separated by filtration (and need to be landfilled),
while the treated saline wastewater is discharged.The effluent of the acidic scrubber is
either neutralised and treated together with the effluent of the neutral scrubber or is
purified and HCl reused.

Semi-wet
wet process

Due to stricter regulations on the discharge of saline wastewater, many incineration plants
are introducing evaporation to eliminate liquid discharges completely79. Wet processes are
therefore being converted to semi wet-wet processes generating dry solid residues. This is
already the case for German and Austrian plants. This process is similar to the wet
technique but the liquid effluent is then sprayed in the gas and the liquid evaporated. This
system produces dry residues classified as hazardous waste.

79

Economic evaluation of the Draft
Commission, DG XI, AEA Technology, December 1996

Incineration Directive, a report produced for

the European

35

It is difficult to present a detailed repartition of the various types of incinerators
currently in activity. The following statistics80 present the situation for the period
1993-1996 and for plants with a rather large capacity. About 15% of the total
capacity use a dry process for gas treatment, for 25% a semi-dry process is
employed, for about 20% semi-wet wet processes are in use and about 40% wet
processes are used. The distribution of treatment capacities is different in the various
Member States. In general, the capacities for dry processes have decreased at the
expense of other processes. The stricter emission requirements for incinerators as
proposed in the Directive on waste incineration are likely to enhance this trend.

80

European Energy from Waste Coalition, Energy from Waste Plants: Databook of European Sites,
Report prepared by Juniper Consultancy Services Ltd, November 1997. This figure refers to plants with
a capacity of more than 30,000 t/year.

36

Additional cost for PVC incineration

ANNEX 2

The figures in the following table81 represent the range of additional costs for the
incineration of PVC in comparison to municipal solid waste. The lower figures apply
to flexible PVC containing 25% chlorine, the higher figures to rigid PVC containing
53% chlorine. The average figures apply to a PVC material mix with 45% chlorine,
i.e. composed of 70% rigid PVC and 30% flexible PVC.

Average and range of
additional cost for PVC
incineration
/ton of PVC

Without stabilisation of
the residues
average and min/max
value
With stabilisation of the
residues
average and min/max
value

Dry System

Semi-Dry

Wet

Lime

Sodium
Bicarbonate

Lime

196
95 – 234

274
144 – 327

165
84 – 206

Lime /
NaOH

19
-1 – 29

Semi-Wet,
Wet

Lime /
NaOH

121
57 – 147

290
154 – 347

334
172 – 396

244
127 – 305

19
-1 – 29

186
96 – 226

81

Bertin Technologies, The influence of PVC on quantity and hazardousness of flue gas residues from
incineration, Study for DG XI, April 2000

37

˛
ANNEX 3

PVC waste management scenarios established for the economic and environmental
analysis 82

Scenarios of future waste management across the EU and six of the applicant countries have
been developed in order to carry out the economic and environmental analysis. The business
as usual (BAU) scenario is based on current destination of PVC waste across Western
Europe as made available by EuPC and the present rate of MSW incineration. The present day
incineration rate of main PVC waste streams is assumed to be in proportion to the general rate
for MSW incineration. To estimate future destinations, a distinction has been made between
implementation of the landfill
themselves to the strict
Member States which will limit
directive and Member States which are likely to go beyond EU rules, substantially reducing
the landfilling of raw organic waste (e.g. Austria, Germany, the Netherlands, Sweden) by
increasing incineration. The first group of Member States are also expected to increase
incineration capacity over the next two decades, but the final rate achieved is assumed to be
lower because of the lower starting point and the poorer economic circumstances of some of
the countries concerned. Accession countries have been included in this first group.

The obtained incineration rates have been applied to the remaining quantities after deduction
of PVC waste that
its
is mechanically recycled. Given the current
development, feedstock recycling has not been considered in the study. Mechanical recycling
has been assumed to develop as predicted under the baseline scenario developed in the
mechanical recycling study83. Thus recycling of post-consumer PVC waste will increase from
about 3 per cent today to about 9 per cent by 2020.

limited state of

Three alternative scenarios for diversion of PVC from incineration have then been elaborated.
The first two are based on the assumption that PVC diverted from incineration will go to
mechanical recycling. In the third scenario, diverted waste is sent to landfill.

Scenario 1: This scenario is partly based on the “selective improvement scenario” proposed
in the mechanical recycling study. It is assumed that recycling of most construction wastes
suitable for high quality recycling is encouraged so that the average potential calculated in the
mechanical recycling study is reached. Although suitable for high quality recycling, PVC in
the household and commercial waste category as well as flexible profiles and hoses
(construction category) have however been excluded as no precise cost estimate was
available. It is reasonable to assume that development of recycling potential for these wastes
is therefore further away than for the remaining wastes for which cost estimates were
provided.

Scenario 2: This scenario models mechanical recycling for all suitable types of waste
(construction, household and commercial, packaging, electric and electronic waste) achieving
its absolute full potential in 2010 and continues at this rate until 2020. All waste streams are
recycled at the maximum of recycling potential estimated in the mechanical recycling study.

Scenario 3: In this scenario recycling rates remain unchanged compared to the baseline
scenario. PVC waste diverted from incineration is therefore sent to landfill. The analysis is

82

83

AEA Technology, Economic evaluation of PVC waste management, draft report produced for the
European Commission Environment Directorate-General, May 2000
Prognos, op.cit.

38

limited to the diversion of construction waste to identify the main economic and
environmental impacts of diverting from incineration to landfill. Segregation of PVC from the
other waste streams considered in the study is likely to be more problematic from an
economic and technical perspective.

39