In a well-received presentation at the IERC (International Electronics Recycling Congress) in Salzburg in January 2023, Chris Slijkhuis illustrated, among other things, the enormous administrative effort that companies such as the Müller-Guttenbrunn Group have to make to classify and notify E-Waste - WEEE (Waste of Electric and Electronic Equipment) - when it is shipped across borders. His conclusion: „E-Waste classification has become too complex!“
Before diving into the matter of e-waste classification, however, one must shed light on the legal basis in Europe. The basis for the classification and notification of e-waste is firstly the „mother of regulations“ - the Basel Convention (Annex VIII or IX, if applicable), then the „daughter“ - the OECD Waste Shipment Framework, which differs from Basel, and the „son“ - the EU Waste Shipment Regulation and the EU Waste Codes. In addition to these international requirements, many countries carry out classifications according to their own waste codes for the respective exporting and importing country, which further complicate the procedure. In this context, Y-codes, H-codes, UN-codes, UN-classes, UN-numbers, UN-shipping names and customs codes also come into play. „It's just crazy how complicated it has become to classify a truck with e-waste material,“ Slijkhuis reports from the field.
The analysis of e-waste for hazardousness has become defacto impossible!
The MGG-expert considers the distinction between hazardous and non-hazardous waste according to European guidelines to be extremely complex and downright impossible. The SVHC-list (Substances of Very High Concern) now lists 224 chemicals, the REACH Restriction List even more than 1,000 substances in 59 categories and the POP list lists more than 30 substance groups, of which the industry expects that there could soon be 200 groups. „These lists are getting longer every year, for which more and more disposal solutions then have to be found. Analyses of mixed e-waste for hazardousness are no longer possible in practice,“ Slijkhuis noted.