Miljøprojekt, 959 – Genanvendelse af dansk plast,- pap- og papiraffald i udlandet

Genanvendelse af dansk plast,- pap- og papiraffald i udlandet

Summary and conclusions

The amount of Danish plastic, cardboard and paper waste that is exported for recycling has generally increased during recent years. In connection with paper and cardboard the reason is partly due to the increasing amount that is collected and to the insufficient capacity at Danish recycling factories to process the collected amounts. In connection with plastic waste the question has been whether or not a higher price could be obtained through export for recycling abroad than through processing in Denmark.

Collection of paper, cardboard and plastic waste in Denmark for recycling and export

From "Statistics of plastic wrapping 2001 /17/ " it appears that app. 21,000 tons of plastic wrapping for recycling were collected in 2001 corresponding to 14 % of the potential 150,000 tons. Of the 21,000 tons app. 10,000 tons were exported.

No statement exists of the collection and export of rejected plastic products that do not come within wrapping, but it is estimated that the amount is limited.

Production waste is not calculated. Generally, production waste is well-defined and very clean and therefore it can be sold for milling and recycling in Danish and/or foreign processing companies.

From "Statistics of recycled paper and cardboard 2001 /19/" it appears that app. 720,000 tons were collected in 2001 corresponding to app. 53 % of the potential 1,360,000 tons.

A large part of the collected amount of paper and cardboard is used at Danish factories.

In 2001, app. 445,000 tons of recycled paper and cardboard were exported while total imports amounted to app. 128,000 tons.

Survey of exported amounts - plastic

From "Statistics Denmark, Foreign Trade 2002 /22/ (Udenrigshandel 2002)" it appears that total Danish exports of plastic waste amounted to app. 24,000 tons in 2002. According to "Statistics of plastic wrapping /17/" app. 10,000 tons were plastic wrapping. Therefore, the remaining app. 14,000 tons must have been non-wrapping products and production waste. From "Foreign Trade 2002 /22/" it also appears that app. 2,000 tons of PVC waste was exported.

The main purchasers (in 2002) of Danish plastic waste were:

Germany 7,500 tons
The Netherlands 5,000 tons
India 2,200 tons
USA 2,000 tons
Sweden 1,800 tons
England 1,400 tons
Hong Kong 1,300 tons
China 1,100 tons
Portugal 1,000 tons

Perhaps exported amounts of plastic are re-exported and therefore it has been examined to which countries e.g. Germany exports plastic waste. From Eurostat /23/ it appears that Germany mainly exports plastic waste to the following countries:

Hong Kong 106,100 tons (35 %)
China 51,400 tons (17 %)
The Netherlands 41,600 tons (14 %)
Italy 25,800 tons (8 %)
USA 14,700 tons (5 %)
Belgium 10,000 tons (3 %)
India 8,500 tons (3 %)

Survey of exported amounts – paper and cardboard

From Statistics Denmark, Foreign Trade 2002 /22/ it appears that total Danish exports of paper waste amounted to app. 432,000 tons in 2002.

In 2002, the predominant part (92 %) of the total Danish export of paper went to Germany (51 % ~ 221,300 tons) and Sweden (41 % ~ 178,606 tons).

Next to Germany and Sweden came Norway (4 %), the Netherlands (2 %), Austria (0.7 %) and Italy (0.4 %) – countries to which export most often takes place.

This project especially brings China/Hong Kong and India into focus and direct exports to those countries are limited. According to Statistics Denmark only 7 tons were exported to Hong Kong in 2002 and 4 tons to India while no direct export took place from Denmark to China (the mainland) in 2002.

From Eurostat /23/ it appears that in 2002 Germany's total exports amounted to 3,176,218 tons.

Of this, app. 8 % went to China (app. 266,000 tons), 2 % to India (app. 60,000 tons) and < 1 % to Hong Kong (app. 2,500 tons).

The Netherlands is the main purchaser of paper and cardboard from Germany (app. 860,000 tons corresponding to 27 %) followed by Austria (app. 450,000 tons corresponding to 14 %).

Danish exporters

A number of companies have contributed with information to the project. The companies concerned are: Averhoff & Co. A/S, Danbørs A/S, EUREC Center Danmark ApS, Expladan A/S, Nordic Paper A/S, P.O.N. Genbrug A/S, Replast A/S, Runi ApS, Smørum Papir Gruppen A/S and Uniscrap A/S.

Export of plastic

Most of the collected material is sold by the Danish collectors to German purchasers but a considerable amount is also sold directly to companies or representatives in Hong Kong and China. None of the mentioned collectors state that they sell directly to India.

Sale to Hong Kong and China typically takes place through Chinese representatives who distribute the material to Chinese reprocessing companies.

Therefore, it is difficult to follow the material all the way to the company that would recycle e.g. collected film wrapping waste from Denmark.

In Germany, there are several large-scale purchasers and trading firms.

Two considerable Danish exporters have contacted several of the German companies but only one was interested in giving detailed information about customers in Hong Kong and China.

It has not been possible to obtain specific information from the other German companies because they want to protect themselves and the contacts they might have in the Far East.

Export of paper

Danish export of recycled paper and cardboard is mainly managed by waste paper dealers and the so-called waste paper mediators (i.e. companies who do not collect recycled paper themselves but who arrange resale to Danish factories and export of recycled paper and cardboard collected by waste paper dealers, municipalities etc.).

In addition, a number of cardboard producing companies and conversion industries export cuttings etc. themselves.

In Denmark, there are three mediators of recycled paper and cardboard and two of them organise a substantial part of the exported amount.

In connection with most of the exported amounts, the mediators and waste paper dealers believe that they know which paper factories process the material.

The exporters maintain that in connection with almost 100 % of the paper they know in which pulp the paper ends. The exporters base that on the fact that they deal with people they know and have confidence in.

The amounts the exporters with certainty do not know where are processed are amounts where the receiver e.g. is a warehouse in Hamburg. It is possible that such amounts continue to a German factory for recycled paper, but it is also possible that the amounts are re-exported.

Export of plastic, paper and cardboard waste to Hong Kong, China and India

The most substantial countries outside the EU that import Danish plastic waste (direct or indirect export) are i.a. Hong Kong, China and India. It has not been possible within the framework of this project in detail to investigate the applicable law, i.a. concerning environmental and working environment conditions. However, information has been searched for on the Internet.

Within the field of plastic and paper, Hong Kong and China have fully acceded to Regulation no. 259/93 (transport regulation) /1/, and therefore all types of plastic waste mentioned in the transport regulation section GH and all types of paper and cardboard waste mentioned in section GI freely can be exported to those countries if the Danish local authorities are informed.

Within the field of plastic and paper India has acceded to Regulation no. 259/93 (transport regulation) of the Council of the European Union /1/. However, in connection with plastic waste stated in the transport regulation under GH ^[3], India has informed that they prefer reporting according to "red procedure". That means that export only is permitted if the Danish and Indian authorities have approved it. All types of paper and cardboard waste stated in section GI can freely be exported to India if exports are reported to the Danish local authorities.

Direct export of paper and cardboard waste directly to Hong Kong, China and India is very limited. According to Statistics Denmark, only 11 tons were exported to those countries in 2002. It is impossible to determine if indirect export to these countries might be a possibility; e.g. via Germany or Sweden. Specifications of item numbers show that the item no. representing the largest part of e.g. Danish export to Germany (78 %) only amounts to 3 % of Germany's export of paper waste to China.

Reports on exported amounts to the Danish Environmental Protection Agency According to Regulation no. 259/93 /1/ of the Council of the European Union (EØF) concerning supervision and control of how waste is transferred within, to and from the EU (also called the transport regulation) companies must (when exporting green waste) before export starts and then subsequently each year inform the local authorities of the type of waste in question, of the expected annual amount and of the utilisation method.

Once annually, the municipalities must – for the first time for 2001 – report the information to the Danish Environmental Protection Agency. As recycled paper and plastic are on the list of green waste it should through these reports be possible to get a general idea of the exported amounts.

However, it has appeared that for 2002 the reports from the companies to the municipalities and subsequently on to the Danish Environmental Agency have been very insufficient.

According to Statistics Denmark total exports in 2002 amounted to app. 432,000 tons of paper and cardboard while only app. 7 % of that amount corresponding to 32,187 tons of paper and cardboard was reported to the Danish Environmental Agency.

Also according to Statistics Denmark, a total of app. 24,000 tons of plastic waste was exported in 2002, while only 11 % of that amount corresponding to 2,754 tons of plastic waste was reported to the Danish Environmental Agency.

Rules concerning export of waste

In Denmark, the export of waste is controlled by the rules stated in the EU transport regulation /1/ and by additional Danish rules laid down in the import/export executive order /2/.

The transport regulation distinguishes between waste that is transported across borders of member countries mutually and waste that is transported between EU member countries and countries outside the EU. In addition, the rules distinguish between waste being exported for "removal" (e.g. depositing at a refuse dump or burning without energy utilisation) or for "utilisation" (e.g. for recycling or burning with energy utilisation) ^[4].

According to the transport regulation, export of waste for utilisation in another EU country is in general allowed but in certain cases the transfer has to be reported to the authorities in the importing country, the exporting country or the possible transit countries.

Three different procedures exist – named after the colours of the traffic signal – green, orange and red. The difference between them is primarily that waste covered by the green procedure does not have to be reported to the authorities before transfer takes place, while waste covered by the orange and red procedure has to be reported.

Lists have been compiled of which type of waste has to follow which procedure.

According to the transport regulation the starting point is that the original waste producer, i.e. the person whose activity has produced the waste is responsible for reporting the waste transport. A waste producer can allow an agent to report on behalf of the waste producer, but formally it is still the waste producer who reports in such a situation and it is the waste producer who finally is responsible for ensuring that the waste is treated correctly.

Legislation in Denmark

It is the duty of the municipalities to keep a sharp eye on the export of waste, also including export of non-dangerous waste.

The Danish Environmental Agency has prepared directions (Directions from the Danish Environmental Agency, no. 2 2000) /5/ to be used when utilising the Council's regulation no. 259/93 /1/ concerning supervision and control of waste transport within, to and from the EU.

The directions have been prepared to help the companies that export or import waste and to help the authorities that supervise if the regulation is observed.

Recycling technology

In relation to possible problems connected with export of paper and cardboard to the Far East, there is - according to the reference group of the project - talk about a declining problem. It is expected that Europe in the course of 5-7 years will be net importer of recycled paper. Today, Europe is net exporter of recycled paper with a total export of 2-4 million tons per year.

In connection with export of paper and cardboard collected in Denmark, the reference group of the project has concluded (in the light of information from agents within the field of paper) that there is no great difference between the production of paper and cardboard from returned fibres in Denmark or abroad, also including the Far East. The fractions that in connection with export could constitute a working environment problem are primarily composite materials and perhaps also rolls (ergonomic problems in connection with pre-treatment).

In addition, the member of the reference group called "EUREC Center Danmark ApS" has informed that processing of Danish plastic waste collected by "EUREC Center Danmark ApS" mainly takes place at new and modern factories in Hong Kong and China.

From a number of articles found on the Internet it appears that processing of plastic waste in China takes place at companies ranging from small family enterprises with manual processing techniques and bad outer environment and working environment to rather large factories with modern processing techniques and better outer environment and working environment.

Fodnoter

[3] Exclusive of GH014

[4] On 13 February 2003, the European Court of Justice pronounced sentence in the case C-458/00 the European Commission versus Luxembourg concerning the purpose of transfer of waste (utilisation or removal). The decision of the European Court of Justice means that waste combustion at waste combustion plants with energy utilisation is removal and not utilisation.