Implementation of New Regulations for Statistics in European Waste Law (Selected Chapters)

The European Commission has adopted changes to the Waste Framework Directive (WFD). This affects the existing reporting system in Germany and the methodology for determining the recycling rate for municipal waste.

by ARGUS Statistik und Informationssysteme in Umwelt und Gesundheit GmbH, Öko-Institut e.V., HTP GmbH & Co. KG

1    Introduction
1.1    Background
The European Commission has adopted changes to the Waste Framework Directive (WFD). This affects the existing reporting system in Germany and the methodology for determining the recycling rate for municipal waste.
At present, the determination of the recycling rate in Germany is based on the measurement of material input into waste treatment plants. As a result of the revision of the Directive, the measurement points for recycling will have to be changed in future. The Commission proposes to determine the recycled amount primarily on the basis of the input into final recycling plants or, under certain conditions, on the basis of the output of sorting plants. In addition, it is proposed to estimate recycling quantities by means of average waste flow specific loss rates.
The amendments to the WFD may have multiple and far-reaching consequences for the collection, processing and management of the statistical data and the legal framework. These consequences are to be assessed, explained and evaluated in the project. The municipal waste recycling target for 2020 remains unchanged, but will be gradually raised in the following years to 55% (2025), 60% (2030) and finally 65% (2035). The future rates will be based on the entire municipal waste stream under a new definition.

1.2    Objectives of the Study

In general, the project will develop the necessary procedures for implementing the new calculation methods in German waste statistics. This includes procedures and methods for making estimates as well as for making standard assumptions. Particular attention must be paid to the traceability of municipal waste and to a greater differentiation of certain output paths. As a result, a uniform and methodologically consistent standard for the determination of the recycling rate was aimed, which was developed in close cooperation with the Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU), Federal Statistical Office (Destatis) and the German Environment Agency (UBA).
In order to estimate the recycling quantity compliant with the directive, a methodological proposal had to be developed, which should largely preserve the existing data collection of Destatis. The need for changes in the data collection resulting from this methodology had to be presented and the impact on stakeholders / reporting agents had to be estimated. The following key questions were to be considered throughout the project:
1. Which changes need to be made with regard to the Environmental Statistics Act (UStatG)?
2. Which material flows require alternative data collection?
3. Which recycling rates result from the developed method?

5.14    Methodical Conclusions from the Material Flow Analysis

The main conclusions of the material flow description are the following:
•    The preferred measurement point for determining the recycling quantity is the output from primary treatment for most material flows. At this point, the substance can usually be assigned directly or by calculation (via the proportion of input) to municipal waste. After the first treatment step, the composition and quality of the material flow can usually be assessed well and the material losses in the further treatment can therefore be estimated relatively well by means of loss rates.
•    The determination of both the amount of municipal waste generated and the recycling quantity is hampered by the fact that packaging is assigned to municipal waste only to the extent that it is similar in nature and composition  to packaging from households. Neither waste codes nor clearly defined criteria are available for this distinction. Here, pragmatic approaches are required.
•    Another problem for traceability arises from the fact that waste of the same material but of different origin and quality is usually assigned to the same waste code of LoW chapter 19 after primary treatment and can therefore no longer be distinguished statistically.  
•    We therefore consider the introduction of additional waste codes for secondary wastes (8-digit sub-categories of LoW codes) to be useful for the complete and sufficiently specific recording of output flows. It would be helpful to integrate:
-    specific codes for different plastic fractions, at least for mono fractions and mixed plastics;
-    waste codes for distinguishing between untreated bottom ash from waste incineration (ash before separation of metals) and treated bottom ash from waste incineration (ash after separation of metals);
-    a waste code for the non-ferrous metals fraction separated from waste incineration bottom ash.
•    The determination of recycling quantities based on the input into the recycling processes proves to be difficult in practice, mainly for reasons  of traceability. At the point of entry into the recycling process, the origin of the waste can no longer be reliably determined. This applies in particular to the material flow ‘metal’ (contribution of municipal waste to metal recycling is small; metals may undergo several processing steps; active import and export of metal scrap). Traceability is no longer possible when the metals are processed in the shredder.
•    Differences between the material flows exist, for example, with regard to the coverage of recycling processes by waste statistics. While for some materials (e.g. biowaste, plastics) the recycling processes are within the scope of waste statistics, paper recycling is not covered by the statistical survey. In the case of iron, aluminium and copper scrap, the statistical coverage of recycling depends on whether the scrap in processing meets the end-of-waste criteria.
•    A material flow-specific consideration of the data collection is absolutely necessary, since the task of determining the recycling quantity is very different for the different material flows.
•    For the material flow ‘organic waste’, the Waste Framework Directive clearly defines the input into the biological treatment as measurement point (see Chapter 4.1.2). The necessary data (input quantity; output quantities for disposal and energy recovery) will in future be provided by waste statistics if the differentiation between material and energy recovery also proposed in the project is implemented. The recycling quantity can then be derived directly from the statistical data in accordance with the Directive.
•    Glass waste usually reaches the end-of-waste criteria already after the first treatment step. Thus, the recycling quantity can be determined based on the output of the primary treatment.
•    For the material flow ‘paper’, recycling is usually beyond the scope of the statistical survey. Therefore, the output quantities of the paper sorting plants, which usually consist of defined paper grades in high quality and with low foreign matter content/impurities, can also be used to determine the recycling quantities.
•    For the complex material flow ‘waste electrical and electronic Equipment’ (WEEE) it is very difficult to determine the recycled amount by means of waste statistic. It is therefore proposed to use the recycling quantities from the monitoring of WEEE according to the WEEE Directive for this material flow.
•    Traceability is generally more difficult for mixtures of substances and composite products (bulky waste, WEEE), as these usually undergo several processing steps (first separation according to materials, then material-specific processing).
According to the material flow analysis, the output-based calculation of recycling quantities is the most effective approach for measuring municipal waste recycling. Traceability can be ensured by using output data from  primary treatment. Losses in subsequent treatments can be estimated by standard loss rates. For this approach, the existing statistical survey is basically sufficient (population and survey forms). Necessary changes to adapt the survey to the requirements of the Waste Framework Directive, such as the more specific reporting of recovery routes, can be made without changing the Umweltstatistikgesetz (Environmental Statistics Act).

6    Proposed Methodology for Determination of the Recycling Rate for Municipal Waste
6.1    Methodological Approach
 This chapter provides a methodology for the determination of the generated municipal waste amount and the respective amount of recycled waste. The findings from the previous work packages, i.e. from the Stocktaking, from the Analysis of the New Legal Requirements and from the Material Flow Descriptions are considered in the method development. Subsequently, the developed method is implemented in a material flow model on the basis of real statistical waste data in order to obtain an estimate for the recycling quantity and the recycling rate of municipal waste.
The method proposed here can be described in detail by the following properties and steps for implementation. The first essential feature of the proposed method is the evaluation of the reported outputs of waste treatment plants that form the reporting population of the Waste Statistics Survey. As an exception, the evaluation of biological treatment plants takes place via the reported municipal waste organic inputs, which are corrected by the output quantities for disposal and by the output quantities for recovery operations other than recycling.
Secondly, the proposed method and its implementation are based on a material flow specific evaluation of waste statistics data. For this purpose, the total amount of municipal waste generated is split up into flows of the same or similar types of materials. From the previous investigation steps it is clear that a material flow specific consideration is indispensable in order to ensure the most reliable traceability of plant outputs back to generated municipal waste through the separation of material flows and their specific treatment steps. On the other hand, this also enables the use of specific loss rates, which can be defined as a function of different plant output qualities. Thus, for example, a different loss rate can be defined for metal that is separated after thermal treatment of household waste than for metals that have been separated during mechanical biological treatment (MBT) of household waste. This means that different contaminant or material contents can be taken into account for each treatment path. In addition, the material flow specific approach enables the identification of those treatment facilities in the reporting population that realise the first treatment step of a certain municipal waste flow (‘model plants'). These primary treatment plants are needed to implement the proposed method (see below).
As a rule, this procedure results in the corresponding measuring points for the determination of recycling quantities, being shifted to the output of plants that treat a certain waste flow for the first time.
With the aim of the most reliable allocation of plant outputs to generated municipal waste, the approach is pursued to determine the inputs in recycling operations by the outputs of the directly preceding treatment operation (eventually by using material specific loss rates, see below). In most cases, this procedure results in the measurement points for the determination of recycling quantities being shifted from the input of the recycling operation towards the output of the primary treatment facility for a certain material flow. In principle, a more reliable assignment of plant outputs to generated municipal waste can be made at primary treatment operations, compared to subsequent treatment facilities or recycling plants. The proposed method therefore takes into account the input and output flows of primary treatment plants. Specific standard loss rates are used to consider material losses due to subsequent waste treatment operations until recycling is finished.
With this objective, waste treatment facilities are selected from the Waste Statistics Survey dataset according to query criteria that identify plants with predominantly ‘pure’ input in terms of material (e.g. sorting plants with nearly exclusive input of municipal waste paper). This is done for each specific municipal waste material flow (glass, plastics, paper, residual waste, etc.). For this purpose, detailed data from the Waste Statistics Survey was requested from Destatis (see Annex to final report in German). The reported inputs and outputs of such material flow specific primary treatment plants are clustered by material, and serve as a sample for the extrapolation to the total amount of the respective material flow. The aggregated inputs and outputs of these plant clusters are considered as characteristics of a sample, which describe the treatment of a subset of a waste flow (e.g. glass waste) in a representative way. The reported outputs from these model plants (e.g. glass sorting plants) are scaled in proportion to the total respective waste material reference flow (municipal glass waste), thereby establishing the allocation of the outputs to municipal waste. This is based on the assumption that the ratios of all plant inputs can be used to estimate their shares in the outputs. The selected treatment plant clusters thus serve as a basis for extrapolating their outputs to the total amount of the respective municipal waste flow, whereby the allocation of outputs to municipal waste has already been implemented and taken into account in the extrapolation.
As a next step, at the level of individual EAV keys, those plant outputs are defined that make a (potential) contribution to recycling. Output quantities that are reported for ‘disposal’ (in D-plants) are excluded from this and cannot contribute to recycling in the modelling. As a consequence, those outputs are considered that are reported for ‘recovery’ (in R-plants) or for ‘direct use’ (in other facilities, i.e. not in R- or D-plants), and which can be assigned to materials such as glass, metal, paper, plastic, wood or only to mixed/undifferentiated substances (e.g. 19 12 12 LoW).
Finally, there is a correction of the output quantities for material recovery with material specific standard loss rates, in order to take account of occurring material losses through subsequent treatment steps until entry into the recycling process. By this means, the traceability can be approximately modelled, even if a waste material flow undergoes several treatment steps. Loss rates are used where data is missing or material flows are not traceable. In this study, the respective estimated loss rates come from a comprehensive literature search (Table 1). However, these rates can vary within a broad range which may have a noticeable impact on the amount recycled. In order to determine more accurate loss rates for the cases occurring, it is recommended to carry out further specific investigations of the material quality of plant outputs.
The proposed method will produce an estimate of the total amount of recycled wastes, based on a sample of treatment plants. With the described output-based approach, the reporting population of the Waste Statistics Survey can be maintained. The existing Waste Statistics Survey can be kept widely unchanged, except for a better allocation of the outputs allocated to recovery (differentiation between material and energy recovery) and other measures described in chapter 7 of the headline report (in German), which are already included in the proposed method. Overall, the implementation and application of the proposals from chapter 7 would clearly support the determination of reliable recycling rates and improve the quality of the data.
As a side effect, the proposed method approach provides material flow specific recycling quantities or rates. In this way, approaches for the future improvement of recycling can be improved in a more targeted manner (i.e. based on the material flow).
The methodological proposals for determining the municipal waste amount and the recycling amount are presented in the following chapters, together with the corresponding modelling results.
6.2    Determination of the Municipal Waste Generation
Municipal waste generation is determined using the existing methodology of Destatis as the sum of all primary waste reported as input by the reporting population. The only innovation resulting from the implementation of the Waste Framework Directive is that the waste codes LoW 20 02 02, 20 03 04 and 20 03 06 are no longer attributed to municipal waste.
The determination of the amount of municipal waste generated is thus based on data already obtained in the context of the current state of the Waste Statistics Survey pursuant to § 3 (1) UStatG. However, some adjustments to the survey are required to improve the quality of the data collected. Especially with regard to municipal waste packaging, a more precise differentiation of industrial and household-like packaging must be made. This is because packaging waste according to LoW-subchapter 15 01 is only to be classified as municipal waste, where it is collected from households or where it is similar in nature and composition to packaging waste from households.
The amount of municipal waste generated on which the estimated recycling rate is based is taken from the 2015 Waste Balance (51 128 kt, excluding the amounts of the three above-mentioned LoW-codes with ca. 500 kt) [Destatis, 2017].
Furthermore, the amount of municipal waste collected from industrial packaging is corrected by exclusion of wood packaging (15 01 03 LoW) from municipal waste, as they consist mainly of pallets and are therefore not ‘household-like’, resulting in an amount of 50 488 kt for the municipal waste generation (Table 2).

6.3    Determination of Recycling Rates
With the aim of determining an estimated value for the recycling quantity, the implementation of the presented methodological approach is based on the Waste Statistics Survey in its current state. Thus, the method proposed here for the determination of recycling quantities is based on an evaluation of output data from the Waste Statistics Survey pursuant to § 3 (1) UStatG. Again, some adjustments to the output-side survey will be required in the future in order to improve the quality of the data and to obtain more reliable results, mainly through a differentiation between subsequent energy or material recovery of waste, which is not the case in the survey in its current state. The proposed method is implemented with the aim of determining the quantity of recycling by calculating a linear projection for the total amount of municipal waste on the basis of material flow specific primary treatment plants (see Chapter 6.1). The proposed method is based on an extrapolation of outputs from the primary treatment facilities that almost exclusively accept municipal waste (according to the municipal waste definition through LoW-codes). For each waste material flow such plants are selected and clustered. They represent model plants for processing the fraction of the respective material flows to be recycled. They represent the primary treatment plants, from which certain outputs (if necessary after further processing steps) enter into recycling operations.
By selecting plants that almost exclusively treat a specific municipal waste flow, the outputs of these plants can be assigned almost completely to the respective material stream. The outputs for ‘recovery’ or ‘direct use’ can then be used to estimate the amount of recycling. If necessary, specific loss rates are applied that relate to the output measurement points after primary treatment of a given waste, to take into account material losses up to the point of entry into recycling.
The modelling of the recycling quantities is also based on the detailed data requested from the Waste Statistics Survey (see Annex to final report in German). Since these data do not (yet) have a differentiation between energy or material recovery, this differentiation was estimated by evaluating the LoW-codes in terms of material usability. The results of the implemented method are presented and discussed in the following chapter.

6.4    Results of the Proposed Methodology
Table 2 gives an overview of the material flow specific modelling results for the estimate of the total recycling quantity and the recycled fraction respectively.
As the modelling in the context of the project had to be based on the waste statistics data in their current format, i.e. without the adjustments proposed under other tasks of the project, the results have uncertainties associated in particular with the applied estimates for the differentiation between material and energy recovery, which will be obsolete when this differentiation is already done in the survey. As a consequence, the results can only be regarded as an approximation due to the current data formats, while the proposed method, when applied in future with better data, will gain considerable accuracy, as the applied estimates for the differentiation between material and energy recovery will no more be required.

1)    Calculated as a 20% recycling rate in relation to the amount of non-packaging wood (701 kt, LoW-code) that did not go to incineration plants (522 kt).
2)    Calculated from the amount according to the Waste Balance and from the recovery rate, which is calculated from the quantity prepared for re-use + recycling (573 kt, Table 22) and the quantity under "Electrical and electronic equipment, according to the survey for the initial treatment of electrical and electronic equipment "(718 kt, Table 21) (80%).
3)    Calculated according to the following approach: Loss rate of 50% based on input into treatment plants that are relevant for recovery.
4)    The rate of 71% does not account for possible double counts observed under the task ‘stocktaking of current waste statistics’. If the potential double counts of between 776 kt and 1 021 kt are taken into account, the resulting rate would range between 76% and 78%. If the recycled amount is only related to the input into biological treatment plants, a rate of 83% would result.

The ‘model-based contributions to the total recycled waste’ describe those quantities that can be considered as the contribution of a given waste flow to the total amount recycled. Thus, the percentages of the last column express the ratio of the considered recycled waste amount to the respective generation of the municipal waste material flow. Thus, it is only approximate information in the sense of material specific recycling rates.
The sum of the modelled contributions to the recycling amount from all flows of municipal waste amounts to 22 461 kt. In relation to the total generated municipal waste amount of 50 488 kt, this results in an estimate for the total recycling rate of 44.5%. The official total amount of municipal waste generated, as published in the Waste Balance, differs from the figures in Table 2 (see column Waste Balance), as it does not include the amount of wooden packaging (640 kt) and the three waste types no more included in the municipal waste definition (500 kt) (see Chapter 6.2).
The modelling is based on the average loss rates provided in Table 1. Mixed / non-differentiable outputs were initially taken into account with a standard loss rate of 50%. If a LoW-code indicated a material similarity to the considered material flow, then the loss rate was estimated at only 5%. In the case of minor streams such as wood, street cleaning residues and WEEE, alternative estimates were made, which are explained in the footnotes to Table 2.
It turns out that the four waste flows organic waste, paper/cardboard, glass and mixed packaging/recyclables together account for approx. 19 850 kt, or 88%, making up the largest share of the total recycling amount. The greatest uncertainties in modelling exist for bulky waste and metals in terms of the estimate base, as less than 25% of the respective generated amount arrives in plants with almost pure input of these flows. For the other waste flows, the base for the extrapolation is between 48% for residual household and commercial waste and 90% for textiles.

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published: BMU Bundesministerium für Umwelt, Naturschutz und nukleare Sicherheit, 8|2022
Keywords: Pollution Control, Policy Tax Instruments, Reuse, Reduce, Mixed Waste, EU