Ecomatters has supported Regain Services Pty Limited in an end-of-waste (EoW) assessment and preparation of the assessment report for a production line of their products known as HiCAL. Regain Services Pty Limited is a company that has developed a technology for the treatment of Spent Pot Lining (SPL) waste, a by-product of the aluminium production process. The resulting product is HiCAL which stands for ‘Higher Clinker ALite’, a mineral-rich material used as an additive in the manufacturing of Portland cement. Unlike other SPL disposal practices, Regain’s solution introduces environmental benefits by transforming hazardous waste material into a valuable product that is safe for transport.
The product compliance
The dossier that has been developed by Ecomatters for Regain had the purpose to demonstrate that the product meets the end-of-waste criteria, as laid down in the European Waste Framework Directive (Directive 2008/98/EC) Furthermore, product compliance is also required with the European regulatory bodies with regard to its transport, use and environmental fate.
Currently, there are no harmonised criteria for the assessment of the EoW status of the SPL-derived material across Europe. Subsequently, national guidelines are to be followed in order to develop an evidence-based report. With respect to Regain’s case study, the guidance provided by the Dutch Ministry and the Irish Environmental Protection Agency (End-of-waste Guidance Document – Environmental Protection Agency) was considered for reference. Further details regarding the EoW status of a substance can be found on our end-of-waste page.
In short, there are four criteria to be fulfilled by the material in order to no longer be considered waste and they are as follows:
- The substance or object is commonly used for specific purposes
- A market or demand exists for such a substance or object
- The substance or object fulfils the technical requirements for the specific purposes and meets the existing legislation and standards applicable to products
- The use of the substance or object will not lead to overall adverse environmental or human health impacts
Given the absence of regulatory criteria for determining that the recycling of SPL results in a product, a case-specific assessment of EoW status for HiCAL was conducted. Ecomatters has assisted in the screening of the documentation provided by Regain to evaluate the specific uses of HiCAL, its demand and compliance with EU chemical safety rules (e.g., Registration, Evaluation, Authorisation and restriction of Chemicals, known as REACH (Regulation (EC) 1907/2006) and the Classification, Labelling and Packaging, known as CLP Regulation (Regulation (EC) 1272/2008)). In particular, the dossier has been structured to provide a description of both waste and final products with respect to sourcing, management and auditing procedures. In order to evaluate the first criteria, the final (recycled) product was investigated for its application and then compared to similar products already present in the market. As for the second criteria, an analysis of the demand and market for both the final and competing products was available as supporting evidence. As part of the third criteria, the regulatory status of the final product was covered as well as its compliance with EU chemical safety rules and available EU standards. Finally, the fourth and last criteria focused on the adverse effects that the substance has on the environment and human health and its environmental fate; the documentation provided was screened to evaluate the applicability and compliance to EU regulations in regard to safety for humans and the environment for HiCAL intended application.
Following the positive outcome of this assessment, an EoW declaration has been drawn up to support the evidence that HiCAL products meet the four criteria reported in the European Waste Framework Directive.
“Ecomatters conducted an end of waste assessment for Regain HiCAL products. We found working with Ecomatters to be a very satisfying experience. They brought a well-structured approach to the assignment and provided comprehensive analysis of the information provided to them. The resultant End-of-waste Evaluation Report is a valuable asset for our enterprise. It was a pleasure to work with such professional and knowledgeable people.
Bernie Cooper, President and Managing Director, Regain”
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