Statement on the discussion draft

The German Waste Wood Ordinance is to be amended by mid 2021. The BAV e.V. is intensively involved in the amendment process as the voice of the German waste wood industry.

On 29.05.2020, BAV e.V. submitted its statement on the discussion draft to the Federal Environment Ministry. The Waste Wood Association views the high practical relevance of the first draft regulation as very positive. We welcome the retention of the four categories of waste wood, as they ensure high-quality processing and recycling of waste wood. We also believe that the improved and supplemented rule presumption will make a decisive contribution to further increasing the sorting quality.

There has been much discussion in recent months as to how a regulation giving priority to material recycling over energy recovery according to the five-level waste hierarchy of the Closed Substance Cycle Waste Management Act could look like. The formulated proposal to regulate priority for A I with a quota and to maintain equal priority for the remaining categories is a good way of implementation which we support. The material quotas are certainly ambitious, but they must also be technically possible or economically reasonable in individual cases.

Sampling during the process is described in the draft, but in our view there is no provision here that would allow batch management to be abolished at the same time. This should be able to be omitted if compliance with the limit values is confirmed by at least 10 consecutive analytical values. The discontinuation of batch management is particularly important for reprocessing companies whose storage areas are limited. A material recycling of waste wood is otherwise made considerably more difficult for these companies.

The new regulations on sampling, analysis and statistical evaluation procedures may only be introduced under the condition that it is scientifically proven that the proposed procedures for sampling, analysis and statistical evaluation procedures are suitable to ensure a higher degree of quality assurance of sampling and analysis than the regulations of the currently valid Waste Wood Ordinance. The fulfilment of the high quality requirement must also be ensured in future, in particular that no accumulation of pollutants occurs in the material cycle (§ 7 III KrWG). In the view of the FOT, this has not yet been conclusively proven.

In order to ensure high-quality material and energy recovery, it must also be possible in future to combine different types of waste wood of different categories in the production of secondary raw materials in compliance with the legal requirements for subsequent high-quality recovery.

The detailed statement is available here in German.

Waste wood meeting in Zurich

BAV-european-waste-wood-assosiation

The European waste wood working group of the BAV will meet in Zurich from 09-10.06.2020. Stakeholders from the waste wood industry from all over Europe will come together.

European exchange

The Working Group Europe is a platform for exchanging information on innovations and trends at the European scale. In 5 presentations, the speakers will report on the waste wood markets in Europe. We talk about legal regulations in your individual countries. About recycling channels or about future power plant projects. The meeting is held twice a year in English.

We are particularly delighted to be able to hold the conference in Zurich.  A big thank you for this to Swiss Krono, one of the most important chipboard producers in the world.

Join our team

Write to me if you would like to attend one of our meetings as a guest.

If you have an interesting waste wood topic that you would like to report on, feel free to contact me.

Are you interested in becoming a member of our association? Then you will find further information here.

Europe – Titanium dioxide is classified

The classification of titanium dioxide as “carcinogenic by inhalation” has been made. It applies only to mixtures in the form of powder containing at least 1% titanium dioxide in particulate form or incorporated into particles with an aerodynamic diameter of ≤ 10 μm.

A motion of 30.01.2020 against the classification did not find a majority in the European Parliament.

The objection period by the Council of Member States and the European Parliament ended without objection on 04.02.2020.

The CLP Regulation, including the regulations on titanium dioxide, was published in the Official Journal of the EU on 25 February 2020. It will enter into force 20 days after its publication in the Official Journal. Thereafter, an 18-month transition period will apply so that the classification can be implemented throughout the supply chain.

From 1 October 2021, the adaptations in Annex VI of the CLP Regulation will be mandatory everywhere.

You can download the text of the regulation here.

European waste wood meeting

Waste wood meeting in Salzburg

The European working group of the BAV will meet in Salzburg from 22-23.05.2019. Stakeholders from the waste wood industry from all over Europe will come together. In 6 presentations, the speakers will report on the waste wood markets in Germany, Austria, Switzerland, France, Benelux and the UK.

European exchange

More and more internationally active companies organise themselves in the German Waste Wood Association. The Working Group Europe is a platform for exchanging information on innovations and trends at the European scale. The conference is held twice a year in English. It is exclusive for BAV members.

We are particularly delighted to be able to hold the conference at the member company UNTHA shredding technology.

Join our team

If you would like to report on the waste wood market in your country, you are welcome to contact us. Are you interested in becoming a member of our association? Then you will find further information here.

Amendment of the German Waste Wood Ordinance

The amendment of the German Waste Wood Ordinance is forthcoming. The regulations are expected to be amended in 2020.

The BAV e.V. has formulated its wishes for amendments to the Waste Wood Ordinance in a position paper. This document summarises the positions taken by the BAV Working Group on Waste Wood Ordinance.

The BAV position paper on the amendment of the Waste Waste Ordinance can be downloaded here: BAV e.V. Positionspapier Novellierung AltholzV Stand 2018-07-18 (only in German)
The proposed change to the presumption of rule can be found here:
BAV e.V. Vorschlag Regelvermutung 2018-07-20 (only in German)

We will also report on the further process as part of our Wast Wood Conference (19.09.2019, Munich).

UFO Plan Study Amendment of the Waste Wood Ordinance

The study “Evaluation of the Waste Wood Ordinance in view of a necessary amendment” is carried out by the IWARU – Institute for Infrastructure – Water – Resources – Environment under the direction of Prof. Dr. Sabine Flamme. The project is scheduled to take 15 months from the date the contract is awarded. The final report is to be published in mid-2019.

Subject of the research project:

Within the framework of the research project, the existing waste wood ordinance will be reviewed. Where are the implementation deficits of the current regulation? Which changes due to technical and analytical progress have to be taken into account? How is the monitoring of exports and imports of scrap wood carried out and where are there deficits? From this, recommendations for action are developed. A material flow analysis of the waste wood material flows will also be prepared in order to estimate possible effects of the proposed solutions on the material flows.

Titanium dioxide: Decision postponed again

On 07 March 2019 the Commission held a special meeting on the reclassification of titanium dioxide. Again no agreement could be reached. The procedure will now only be dealt with again after the European elections (23 to 26 May 2019). The BAV expects a decision in autumn 2019 at the earliest.

The decision as to whether or not titanium dioxide should be classified as “presumed carcinogenic by inhalation” should already be taken at the meeting of the REACH Committee on 14 February 2019. Even in this vote, the qualified majority required for the classification could not be reached.

At the beginning of February 2019, concerns on classification could be raised within the framework of a consultation procedure. Around 500 comments were submitted. The BAV also participated in this process in coordination with our cooperation partner BDE.

Context Briefing

Titanium dioxide – one of the most widely used pigments worldwide

Titanium dioxide (TiO2) is a white pigment which is used in the food, cosmetics and pharmaceutical industries as well as in technical applications for the production of paints, lacquers, plastics and textiles. It is one of the most widely used pigments worldwide.

Titanium dioxide – Classification as “Cancerogen 2”?

The European Chemicals Agency (ECHA) is currently examining whether titanium dioxide should be classified as “Cancerogen 2” on the basis of a report by the French Food, Environment and Safety Agency (ANSES). If this assessment were to be made, titanium dioxide would have to be treated as a substance suspected of being cancerous in future. For years, however, it has been investigated whether and to what extent the oral, dermal or inhalative intake of titanium dioxide has health effects on human health – to this day, however, the question has not been clearly answered scientifically. The Scientific Service of the German Bundestag has compiled an overview of current studies: Possible health effects of titanium dioxide on the human body – Current discussion and literature / Mögliche gesundheitliche Auswirkungen von Titandioxid auf den menschlichen Körper – Aktuelle Diskussion und Literatur.

Effects on the waste wood industry

A classification could have far-reaching consequences for the waste wood industry. All wood waste containing more than 1 % by mass of titanium dioxide would have to be treated as hazardous waste if classified as “carcinogen 2”. According to the study „Analysis of the socio-economic impacts of a harmonised classificationof Carcinogen Category 2 for titanium dioxide (TiO2)“, wood coatings or decor papers, for example, could contain significantly higher values. The study gives rise to the fear that many waste wood assortments will have to be treated as hazardous waste in the future. Classification would also pose a great challenge to the processing of waste wood, since titanium dioxide is said to be of particular concern in dust form.

Industry and politics against reclassification

In Germany, there is strong resistance from industry to the planned classification. Our cooperation partner BDE e.V., which represents the interests of BAV e.V. at the European level, has made considerable efforts together with the associations VCI and BDI to combat the planned reclassification. From the point of view of the waste wood industry, we have also drawn the attention of the Federal Government to the drastic consequences for the recycling of waste wood in Germany.

In the meantime, the federal government has spoken out against the classification. The focus must be on protecting workers from dust emissions during the production and processing of titanium dioxide. This would require the introduction and compliance with harmonised workplace limit values throughout Europe, as is already the case in Germany.

Together with the BDE, the BAV supports the proposal of the German federal government. However, a final decision by the Commission is not expected before February 2019.

Waste wood trends in Sweden and Europe

Things are going to change.

Mario Montevirgen of the Swedish waste wood specialist Falkenbergs Returflis is also convinced that a lot will change in some EU member states in the course of the next one to two years. He sees different resource-political strategies as characteristic for this: While Germany is looking for a new orientation after the introduction of the Renewable Energy Sources Act, the United Kingdom and France are focusing on new capacities for biomass plants. In the Baltic States and Eastern Europe, there are signs of a strengthening of the engineered wood industry, while Sweden favours the expansion of its waste wood plants.

According to Mario Montevirgen, Germany wants to increase its domestic waste wood volume from 7.7 million tonnes to over eight million tonnes by 2021. The extent to which the capacity of 6.5 million tonnes (plus 1.5 million tonnes planned) is to be changed depends not least on the extent to which exports to the engineered wood industries in Eastern Europe and the Baltic States are expanded. Sweden wants to increase its domestic tonnage from 1.1 to 1.3 million tonnes, expand its energy plant capacity from 2.0 million tonnes in 2016 to 2.4 million tonnes in 2021, and is not averse to an increase to the 0.8 million tonnes of imported waste wood.

Norway does not expect any significant changes in view of the expansion of its domestic tonnage from 0,7 to 1,0 million tonnes, exports from 0,4 to more than 0,6 million tonnes and the still open plant capacities. Unlike the United Kingdom, which intends to increase its domestic treatment capacity from 3.7 to 4.3 million tonnes by 2021 and to increase its capacity from 1.6 million tonnes (plus 1.4 million tonnes planned) to 4.5 million tonnes. In return, exports are to be reduced from 0.6 to less than 0.3 million tonnes.

Sweden is looking for a supply partner

As a traditional importer of waste, Sweden is affected by external factors and is dependent on them. For example, the demand for forest chips is expected to change drastically so that imports from overseas have to be considered. As the United Kingdom and France have increased local demand for waste wood due to new plant capacities, their export volumes are also being reduced, so that new supplier countries have to be sought.

The capacity expansions in the Eastern European engineered wood industry are reducing export volumes to Sweden. And finally, other biomass plants can compensate for their bottlenecks with waste wood, which has an impact on demand and prices. On the other hand, according to Mario Montevirgen, Germany would have had to good reasons and new opportunities to trade in to enter waste wood exports with Sweden.

We expressly thank the editorial staff of EU-Recycling Magzins, who published this article in issue 11/2018, page 30. You can download the article in German here: EU-Recycling_11-2018-Altholz.

UK – new biomass plants are expected

UK: 5 million tonnes of waste wood

According to Julia Turner, Managing Director of the UK Wood Recyclers Association (WRA), the UK produces five million tonnes of waste wood, recycles 1.7 million tonnes, uses 1.7 million tonnes as biomass and exports 300,000 tonnes per year. An annual 924,000 tons are used in the wood panel industry and supply 60 percent of the material for chipboard production. In terms of energy, waste wood stands for around 2.9 terawatts of electricity production per year and thus covers one percent of the British energy requirement.

New biomass plants are expected to generate an additional one million tonnes of electricity per year within the next twelve months. In August 2018, plant capacities for 2.1 million tonnes in operation, 1.3 million tonnes in commissioning, 0.4 million tonnes under construction and 0.6 million tonnes were therefore planned, a total of 3,468,000 tonnes. Julia Turner anticipates a number of specific factors – effects of the new fire protection plan, amended permits, possible changes of government and Brexit, to name but a few – that could affect the market for scrap wood and generate demand of between 4.4 and 5.9 million tonnes.

We expressly thank the editorial staff of EU-Recycling Magzins, who published this article in issue 11/2018, page 30. You can download the article in German here: EU-Recycling_11-2018-Altholz.

Waste wood market in France

In France – Sylvain Laurent of FEDEREC explained on the BAV-Altholztag (BAV-Waste Wood Conference) – around six million tonnes of waste wood are collected annually. Every year, the collection rate is expected to increase by six percent; 69 percent of the wood collected is recycled and the trend is rising. According to Cambon, 36 percent of its volume consists of industrial waste and construction and demolition waste, 23 percent of the remainder from “industrial activities” and 14 percent of packaging waste. The 27 percent from household and municipal waste is due to an extended producer responsibility for furniture in which two organisations – Éco-mobilier and Valdélia – participate.

19 percent of the waste wood is recycled in the French wood panel production and a further 19 percent in foreign industrial plants. 31 percent are used for energy recovery, while 31 percent end up unused in incineration or landfills. In 2017, the industry was able to market more waste wood than in the previous year, which helped to reduce wood storage from just under 300,000 tonnes to around 60,000 tonnes within a year, but led to a drop in prices. All in all, the turnover of the French wood industry of 169 million euros is said to have fallen sharply in recent years due to unfavourable market conditions.

We expressly thank the editorial staff of EU-Recycling Magzins, who published this article in issue 11/2018, page 30. You can download the article in German here: EU-Recycling_11-2018-Altholz.

Waste wood markets in Europe

Last week, at the invitation of the member company Renewi, the meeting of the European Working Group of the BAV-Bundesverband der Altholzaufbereiter und -verwerter e.V. took place in Amsterdam.

The event focused on the European waste wood markets, their changes and challenges. The goal of the meeting is networking, knowledge transfer and a better understanding of the markets in neighbouring European countries.

Presentations and market reports from Great Britain, Belgium, the Netherlands, Sweden and Germany highlighted the developments in the individual countries. Above all, Germany, the largest market for waste wood in Europe, is facing major challenges with a view to the end of the promotion period for waste wood power plants.

The next meeting of the working group is scheduled for spring 2019.

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