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Hungarian Waste Management Federation

HOSZ

The Hungarian Waste Management Federation (Hulladékgazdálkodók Országos Szövetsége, HOSZ) is principally the industry federation of recycling companies in Hungary.

Lobbying Activity

Response to Targeted amendment of the European List of Waste as regards waste batteries and wastes from their treatment

8 Nov 2024

We welcome the opportunity to comment on the draft EU Decision amending Decision 2000/532/EC as regards an update of the list of waste in relation to battery-related waste. We would like to make the following proposals: 1) Speeding up waste shipment and permitting procedures We would like to stress that in parallel with adopting harmonised hazardous classifications for battery wastes it would be utterly important to accelerate and simplify the procedures (the procedures and not the technical conditions) linked to waste shipments and the permitting of waste treatment, since the overly complex legal requirements and the attitude of the authorities may even have the unwanted effect of steering companies towards illegal activities. In our opinion the most important procedure to accelerate is the procedure of prior written notification and consent for the transboundary shipment of hazardous wastes, and this should be solved in the 1013/2006/EK and 2024/1157/EU Waste Shipment Regulations. 2) Battery manufacturing wastes Hungary is in a special position in the EU regarding battery waste. Because of the tremendous investments into battery manufacturing and the lack of proper treatment of battery manufacturing waste, it is the essential environmental interest of the country that the manufacturing wastes of battery factories fall under strict rules. It is impossible to have a clear overview of the technologies which also change very rapidly. Manufacturers are not transparent about their technologies and developments, partly due to the market competition, and partly due to the use of hazardous substances. Therefore, it is impossible to know which waste contains hazardous components. Based on the above, and taking into consideration the precautionary principle, we propose that all battery manufacturing wastes are assigned an absolute hazardous code. We do not support the non-hazardous mirror codes below and similar codes which would allow for the circumvention of rules and the classification of hazardous wastes as non-hazardous. 16 06 23 lead-acid battery manufacturing waste other than that mentioned in 16 06 22 16 06 25 lithium-based battery manufacturing waste other than those mentioned in 16 06 24 (for example anode cut-offs) 16 06 27 nickel-based battery manufacturing waste other than that mentioned in 16 06 26 16 06 29 alkaline-based battery manufacturing waste other than that mentioned in 16 06 28 16 06 31 zinc-based battery manufacturing waste other than that mentioned in 16 06 30 16 06 33 sodium-based battery manufacturing waste other than that mentioned in 16 06 32 16 06 35 battery manufacturing waste other than that mentioned in 16 06 23, 16 06 25, 16 06 27, 16 06 29, 16 06 31 and 16 06 33 16 06 12 other waste sodium-based batteries 16 06 15 waste batteries not otherwise specified other than those mentioned in 16 06 14 We believe that it should be the obligation of battery manufacturers to inform the environmental authorities and interested parties about the hazardous components and hazardous characteristics of their wastes or prove to the authorities if any of their waste is non-hazardous. It will be impossible to list each and every waste type in the legislation with so many new battery types and their manufacturing wastes emerging continuously. We propose the following non-hazardous battery manufacturing waste type: battery manufacturing waste classified as non-hazardous according to the individual assessment and declaration of the environmental authority. And the actual, specific waste classified as non-hazardous according to the above should be distinctly identifiable by its visual, physical, and chemical characteristics. We ask the European Commission to consider and take into account the above proposals when finalising the draft Decision. We also ask that amendments are made to other related pieces of legislation in order to alleviate the administrative burden referred to in point 1).
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Response to Commission Regulation amending Annex III to Directive 2008/98/EC

17 Aug 2016

The Hungarian Waste Management Federation (Hulladékgazdálkodók Országos Szövetsége, HOSZ) is principally the industry federation of recycling companies in Hungary, with its currently 50 members representing a significant proportion of the Hungarian recycling industry. HOSZ is, in line with the position of EuRIC, highly concerned that the proposed Commission Regulation amending Annex III to Directive 2008/98/EC as regards the hazardous property HP 14 (ʻEcotoxic’), based on the outcome of “Study to assess the impacts of different classification approaches for hazard property "HP 14" preferring the calculation method 1 for classification purposes, will adversely impact recycling. An approach relying on chemical analysis, as it is the case with method 1, is technically unfit for characterisation of complex solid waste streams, such as fluff-light fraction and dust from shredding of metal containing waste 19 10 03*/19 10 04. The chemical analysis is suited for assessing homogeneous substances and well-defined mixtures commonly found in virgin materials but absolutely not adapted to the characterisation of solid waste which by nature is heterogeneous and complex. Sampling solid waste coupled a chemical lixiviation of the sample to obtain a homogeneous liquid and exhibit its chemical properties would provide only a very poor indication of the hazardous properties of the waste sample analysed: It would neither be representative of complex materials found in solid waste nor would it be indicative of the bioavailability of hazardous substances. The Study, used as a basis for the draft Commission Regulation, is based on an extremely limited dataset not allowing to draw conclusions relying on solid scientific evidence. Out of only 11 samples assessed for the pair 19 10 03*/19 10 04, 10 already had a baseline classification as hazardous and only 1 had a baseline classification as non-hazardous (while the majority of Member States currently classify this stream as non-hazardous), which makes it easy to assert that the consequences of a reclassification would be minor. The Study explicitly acknowledges “the lack of availability of characterisation data from chemical analysis” in general (p.91, sec. 5.4.1, 1. par.) and the lack of data for fluff and dust from metal shredding (p.15, above the table and p.126, sec. 6.4.5, last par.). Socio-economic impacts resulting from a probable reclassification of fluff-light fraction and dust from metal shredding from currently non-hazardous to hazardous, on the basis of an unfit method, would seriously disrupt if not render impossible recycling of streams reaching high recycling targets and force facilities to temporary or definitively cease operation for no environmental benefits. Applying the method 1 for classification of fluff-light fraction and dust would from a scientific viewpoint be irrational. Given the limitations of the chemical analysis approach, it would be justified to develop a harmonised method which is scientifically fit for purpose of assessing the ecotoxicity of complex solid waste streams instead of relying on a preferred method 1 which is inadequate for assessing HP 14 for complex streams. As long as such a method is not developed, complex solid waste streams such as fluff-light fractions and dust must be exempted from any method based on chemical analysis for assessing HP 14 and regulatory changes to incorporate such a method in the legislation. HOSZ urges the European Commission and the Technical Adaptation Committee to refrain from approving any proposal relying on chemical analysis for the assessment of the ecotoxic property of waste HP 14 applicable to fluff-light fraction and dust until a proper harmonized method fit for the purpose of characterising complex solid waste streams is set up. This response was prepared under a very short period of time given the short period left to stakeholders to react to this consultation.
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