What is Green List waste? A regulator’s perspective Fiona Donaldson National Waste Policy Unit SEPA

What is Green List waste?  Policy priorities  What the law says Green List is  Green List from co-mingled collections  Regulatory approach

Getting to compliant waste exports  The right type of waste  At the right quality  To the right country  For the right type of ESM recovery  In compliance with the applicable control system

What is Green List waste? The legal answer:  Annex III to WSR –List of wastes subject to the general information requirements laid down in article 18

What isn’t Green List waste?  Any waste that isn’t listed in the Green List  Any waste listed in any other Annex to the WSR –Y46 waste collected from households - unless appropriately classified under a single entry in Annex III  Mixtures of waste – even if all Green List components  “Contaminated” Annex III waste If it isn’t Green List export it is either:  Prohibited, or  Subject to notification controls

Mixtures of Green List waste  Notification unless listed in WSR Annex IIIA  Annex IIIA – currently empty  Annex IIIA to non-OECD? Notification pending further “write round” and revised Green List regulation

Contaminated with other material to the extent:  Increases the risks associated with the wastes sufficiently to render them appropriate for submission to the procedure of prior written notification and consent, when taking into account the hazardous characteristics listed in Annex III to Directive 91/689/EEC Or  Prevents the recovery of the wastes in an environmentally sound manner

Material outputs from MRFs destined for export Co-mingled household waste input must be: “properly sorted” And therefore is not:  Y46 waste collected from households - unless appropriately classified under a single entry in Annex III, or  A mixture of wastes; or  Excessively contaminated

Key Annex III entries B Solid plastic waste: The following:  Plastic or mixed plastic materials, provided they are not mixed with other wastes and are prepared to a specification B Paper, paperboard and paper product wastes The following materials, provided they are not mixed with hazardous wastes:  Waste and scrap of paper or paperboard

Key Annex III entries B Glass waste in non-dispersible form:  Cullet and other waste and scrap of glass except for glass from cathode-ray tubes and other activated glasses

Properly sorted?

Paper – key non EU destinations

Plastic – key non EU destinations

The regulatory challenge  Rapidly increasing trade  100K containers  Port inspections – too late!  Must get it right at the MRF  Upstream regulation is key

If we don’t get it right?  No public confidence  No end user confidence  Miss recycling recovery diversion targets  Infraction  Additional legislation

MRF audits  MRFs and metals processors audited  Approx 2/3 good or OK  Approx 1/3 cause for concern –Marginal or poor quality output –Poor record keeping –Don’t know where output goes

The MRF as a quality material manufacturer Can operators demonstrate:  Outputs are consistent?  They know what the contaminants are?  The waste has been “properly sorted”?  A documented audit trail to demonstrate consistent outputs of known parameters?  Where the material goes and how it’s used?

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