Waste industry experts join forces over proposed wood waste classifi cation changes


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ndustry experts have joined forces and written to the Environment Agency to voice their concerns over proposed changes to the classifi cation of waste wood.


Representatives from a number of organisations have jointly penned a letter outlining their worries about how the EA is currently proposing mixed waste wood should be recorded at the front end of the wood recycling and recovery process.


T e organisations include; the Wood Recyclers Association (“WRA”), United Resource Operators Consortium (“UROC”), the National Association of Waste Disposal Offi cers (“NAWDO”), the Local Authority Recycling Advisory Committee (“LARAC”), the Wood Panel Industries Federation (“WPIF”), major waste management companies such as FCC, Veolia and Suez, as well as other key stakeholders. T ey also have the full support of the two main industrial end users of waste wood – panel board manufacturers and biomass energy suppliers.


T e proposed change follows concerns that treated waste wood has being described as untreated, clean grade A material and ending up in non IED Chapter IV-compliant boilers. At the same time, the European Commission highlighted the German wood recycling market records around 15% of its waste wood as hazardous, compared to less than 0.5% in the UK.


British wood recyclers say this is because in Germany hazardous waste wood is a commodity, and has established and accepted end user routes which do not exist in the UK.


T e EA’s new proposal is that if the potentially hazardous properties of a mixed waste wood load cannot be properly assessed at the front end, the whole load may have to be classifi ed as hazardous.T e wood industry experts are now working with the EA and carrying out testing and analysis to prove the UK’s percentage is very small and the potential for environmental harm is minimal.


Andy Hill, Chair of the WRA, said the UK’s wood industry and its associated stakeholders were in complete agreement that the proposals were unnecessary.


“We’re concerned this could have a catastrophic eff ect on the industry’s two major consumers of mixed waste wood, panel board and energy suppliers, both of whom contribute a huge amount to the UK’s economy and recycling/recovery targets, without proper evidence that it is required or justifi ed,” said Andy.


“As a joint working group, we have come together to ask the EA to reconsider its position and allow us time to move this situation forward without any knee-jerk reactions.”


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T e letter to the EA cites the following concerns: • Around 40% of waste wood is generated via household waste recycling sites (“HWRCs”). Additional separation or consigning mixed waste wood as hazardous will mean signifi cant costs for local authorities and would reduce the national recycling rates by 2-6% per year;


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If this approach is adopted in Wales, it would be disastrous for Welsh Local Authorities, who are expected to reach a recycling rate of 64% by April 2020, otherwise facing a fi ne of £200 for every tonne below;


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If a diff erent system is adopted in Wales it could cause issues, particularly along the Wales and England border;


• Local authorities may be unwilling to accept mixed waste wood at HWRCs, which could increase fl y- tipping;


• Landfi lling of a recyclable waste stream will increase; • T ere are minimal disposal routes for hazardous waste wood in England and none in Wales. Hazardous waste landfi lls have strict waste acceptance criteria, one of which is a 10% organic limit, which hazardous waste wood would fail;


• T e two major customers for waste wood have confi rmed they would no longer be able to accept and process it;


• Waste facilities that accept and treat waste wood will not have the required planning and permitting authorisation to manage hazardous waste;


• Public perception will be that furniture they buy for their garden is hazardous;


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Insurers and fi nance providers have indicated they would not be willing to support sites processing mixed waste wood if it was classifi ed as hazardous.


Energy suppliers and panel board manufacturers account for 80% of the UK’s total waste wood market, and already recognise there is a small risk of hazardous waste wood in their feedstock from recyclers. T ey have thorough testing regimes in place to ensure levels are consistently acceptable for their specifi c processes and do not pose a danger to the environment or human health. Both industries are also heavily regulated themselves and have had no issues to date.


Since learning of the proposed changes, many WRA member companies have been carrying out tests at their sites. T e early results have been shared with the EA and indicate .01 to .02% of total waste received during the


past month as having been hazardous. T ese tests will continue.


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