End-of-waste Criteria for Aluminium and

Aluminium Alloy Scrap:

Technical Proposals
Lenka Muchov and Peter Eder

EUR 24396 EN - 2010

The mission of the JRC-IPTS is to provide customer-driven support to the EU policy-making

process by developing science-based responses to policy challenges that have both a socioeconomic as well as a scientific/technological dimension.

European Commission
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JRC 58527
EUR 24396 EN
ISBN 978-92-79-15990-9
ISSN 1018-5593
doi:10.2791/43228
Luxembourg: Publications Office of the European Union
European Union, 2010
Reproduction is authorised provided the source is acknowledged
Printed in Spain

Preface

PREFACE
This report is the JRC-IPTS contribution to the development of the end-of-waste criteria for
aluminium scrap in accordance with Article 6 of Directive 2008/98/EC of the European
Parliament and of the Council on waste (the Waste Framework Directive).
The purpose of end-of-waste criteria is to avoid confusion about the waste definition and to
clarify when certain waste that has undergone recovery ceases to be waste. Recycling should be
supported by creating legal certainty and an equal level playing field and by removing
unnecessary administrative burdens. The end-of-waste criteria should provide a high level of
environmental protection and an environmental and economic benefit.
The recitals of the Waste Framework Directive identify scrap metals as a possible category of
waste for which end-of-waste criteria should be developed. Consequently, the Environment
Directorate-General requested from the JRC-IPTS a study with technical proposals on end-ofwaste criteria for aluminium and aluminium alloy scrap.
This report delivers the results of the study. It includes a possible set of end-of-waste criteria
and shows how the proposals were developed based on a comprehensive techno-economic
analysis of aluminium and aluminium alloy recycling and an analysis of the economic,
environmental and legal impacts when aluminium scrap cease to be wastes.
The report has been produced by the JRC-IPTS based on the contributions of experts from
Member States and the stakeholders by means of a TWG. The experts contributed in the form of
written inputs and through participation in a workshop organised by the JRC-IPTS in July 2009.
The report also used the results of previous research carried out by the JRC-IPTS from 2006 to
2008 and described in the reports 'End-of-waste criteria' and 'Study on the selection of waste
streams for end-of-waste assessment'.

TABLE OF CONTENTS
PREFACE ...................................................................................................................................................1
GLOSSARY ................................................................................................................................................3
INTRODUCTION ......................................................................................................................................5
1

ANALYSIS..........................................................................................................................................7
1.1
Scrap sources ..............................................................................................................................7
1.2
Secondary aluminium production.............................................................................................11
1.3
Recycling processes..................................................................................................................11
1.4
Industry structure......................................................................................................................14
1.5
Economy and market ................................................................................................................15
1.6
Specifications and standards.....................................................................................................18
1.7
Legislation and regulation ........................................................................................................19
1.8
Environmental and health aspects.............................................................................................20

END-OF-WASTE CRITERIA........................................................................................................23
2.1
Rationale for end-of-waste criteria ...........................................................................................23
2.2
Conditions for end-of-waste criteria .........................................................................................23
2.3
Outline of end-of-waste criteria................................................................................................24
2.4
Criteria on product quality........................................................................................................25
2.5
Criteria on input materials ........................................................................................................33
2.6
Criteria on treatment processes and techniques ........................................................................34
2.7
Quality assurance......................................................................................................................36
2.8
Application of end-of-waste criteria .........................................................................................38

IMPACTS .........................................................................................................................................39
3.1
Environmental and health impacts............................................................................................39
3.2
Economic impacts.....................................................................................................................40
3.3
Legal impacts............................................................................................................................42

CONCLUSIONS ..............................................................................................................................51

REFERENCES.................................................................................................................................53

ANNEXES .................................................................................................................................................55
Annex 1. Summarised standards en 13920 on aluminium and aluminium alloy scrap...........................56
Annex 2. Aluminium scrap categories according to Institute of Scrap Recycling Industries (ISRI)......58
Annex 3. Summarised criteria ................................................................................................................59

Glossary

GLOSSARY
APEAL
ASR
BIR
CFCs
ECHA
EEE
EFR
ELVs
EoW
EU
EUROFER
FER
GHG
JRC-IPTS
LME
PBT
PVC
REACH
SDS
TWG
UBCs
UNECE
vPvB
VAT
WEEE
WFD

Association of European Producers of Steel for Packaging

Automotive shredder residue
Bureau of International Recycling
Chlorofluorocarbons
European Chemical Agency
Electrical and electronic equipment
European Ferrous Recovery & Recycling Federation
End-of-life vehicles
End-of-waste
European Union
European Confederation of Iron and Steel Industries
Federacin Espaola de la Recuperacin y el Reciclaje
Greenhouse gas
Joint Research Centre- Institute for Prospective Technological Studies
London Metal Exchange
Persistent, Bioaccumulative and Toxic chemicals
Polyvinyl chloride
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)
Safety Data Sheet
Technical Working Group
Used beverage cans
United Nations Economic Commission for Europe
very Persistent, very Bioaccumulative
Value added tax
Waste electrical and electronic equipment
Waste Framework Directive

Introduction

INTRODUCTION
Background
According to Article 6 (1) and (2) of the new Waste Framework Directive (WFD) 2008/98/EC,
certain specified waste shall cease to be waste when it has undergone a recovery operation and
complies with specific criteria to be developed in line with certain legal conditions, in particular
when there is an existing market or demand for the material and the use is lawful and will not
lead to overall negative environmental or human health impacts. Such criteria should be set for
specific materials by the Commission in comitology. The end-of-waste criteria mechanism was
introduced to further encourage recycling in the EU by creating legal certainty and an equal
level playing field and removing unnecessary administrative burden.
A methodology guideline to develop end-of-waste criteria has been elaborated by the Joint
Research Centre the Institute for Prospective Technological Studies (JRC-IPTS) and is
documented in Chapter 1 of the JRC "End-of-Waste Criteria" report. The European
Commission preparing proposals for end-of-waste criteria for specific waste streams according
to the legal conditions and following the JRC methodology guidelines. As part of this work, the
JRC-IPTS has conducted a study with the aim to prepare technical proposals for aluminium
scrap.
Aim and objectives
Any proposal by the Commission of end-of-waste criteria needs substantial technical
preparation. Therefore the JRC-IPTS has produced this report with the help of a Technical
Working Group (TWG) composed of experts from the different Member States and involving
experts from all relevant stakeholders. The study includes all the necessary information and as
far as possible makes proposals of end-of-waste criteria for aluminium scrap in conformity with
Article 6 of the WFD. The study was guided by the methodology for setting up end-of-waste
criteria that was developed by the JRC-IPTS.
Process
The technical proposals were developed based on the contributions of experts from Member
States and the stakeholders by means of a TWG. The experts were requested to make their
contribution in the form of written inputs and through participation in the expert workshop
organised by the JRC-IPTS on 2 July 2009. Before the workshop, the JRC-IPTS submitted a
background paper to the TWG in order to prepare for the work, to collect the necessary
information from the experts and to have previously collected information peer-reviewed within
the TWG. Shortly after the workshop, the JRC-IPTS wrote to the TWG with the request for
additional inputs. A first draft of the final report was made available to the TWG for comments
in September 2009. The final report was prepared by the JRC-IPTS based on the inputs and
comments from the TWG throughout the whole process.
Structure of the report
The first part of the report provides a comprehensive overview of aluminium scrap recycling. It
analyses scrap sources, describes the scrap metal recycling processes depending on the source of
the material, and identifies the environmental issues. It also includes a description of the
industry structure, scrap type specifications used by industry, and related legislation and
regulation.
The second part deals with the end-of-waste criteria as such. It identifies the reasons for
developing the end-of-waste criteria for aluminium scrap, i.e. the advantages they offer
compared to the current situation. It then analyses how the basic general conditions for the endof-waste criteria can be fulfilled and finally it proposes outlines of possible end-of-waste criteria
including a quality assurance system.
The third part addresses potential environmental, economic and legal impacts of implementing
the end-of-waste criteria.
5

Analysis

ANALYSIS

The development of end-of-waste criteria requires consideration of the characteristics of waste

streams, the structure of the industry, the economics, the market situation and trade flows, the
existing regulations and standards/specifications, and the environmental and health aspects. The
following sections look at these issues throughout the entire recycling chain of aluminium scrap.

1.1 Scrap sources

One way of classifying scrap is to distinguish it according to its source; from the aluminium
processing (new scrap), and scrap from products after their use (old scrap).
New scrap is generated during the initial manufacturing processes. All secondary aluminium
residues are treated by refiners or remelters. The composition of new scrap is well known and in
principle new scrap does not need any pretreatment process before it is remelted, although
cutting to size might be necessary. New scrap could be considered a by-product and not waste
(Paragraph 1.7). New scrap with paint or coating, excluding cable and composite material of
aluminium and plastic may require special processing.
Old scrap is collected after a consumer cycle, either separately or mixed, and it is often
contaminated to a certain degree, depending highly on its origin and collection systems. Since
the lifetime of many metal products can be more than ten years and sometimes more than 50
years, for instance products for building and construction, there has been an accumulation of
metal in use since the start of the industry.
According to industry, currently around 540 Mt of aluminium products are in use and nearly 8
Mt of old aluminium scrap were generated worldwide in the year 2004. Scrap generation has
doubled since 1990 and is expected to increase further mainly due to the continuous increase of
aluminium content in products such as vehicles over the last 15 years and the improved
collection of packaging materials such as beverage cans. In the EU (data for EU-25), the total
recycled old scrap was 2 Mt in 2004 and the total aluminium in use amounted to nearly 120 Mt.
The key sources of aluminium scrap are shown in Figure 1.

Cable, wire,
EEE and
others
21%

Construction
and building
7%

Transportation
facility and
vehicles
44%

Packaging
28%

Figure 1:

Sources of aluminium scrap.

Another way to classify scrap sources is according to the products in which the metal was used
before it became a waste. The main aluminium scrap sources in this sense are vehicles, metal
products for construction, cables and wires, electrical and electronic equipment and packaging.

Analysis

Transportation facilities and vehicles

The automobile industry is the largest overall market for aluminium application and the largest
source of aluminium scrap. When a car comes to its end of life, it is collected and dismantled.
Approximately 9 million (according to Federacin Espaola de la Recuperacin y el Reciclaje
(FER) the amount may be even higher around 12 million 14 million) end-of-life vehicles
(ELVs) are discarded every year. Cars are primarily composed of metal (about 75 %) and a
range of other materials. Currently, the metal components can be separated and completely
recycled but this leaves a mainly organic residue, which is disposed of in landfills or
incinerated. The metallic parts are separated by physical processes and recovered as ferrous
scrap (iron and steel, comprising 70 % of the total vehicle waste) and non-ferrous metals (5 %),
all of which is recycled. The remaining 25 % is the automotive shredder residue (ASR), which
is composed mainly of plastics, contaminated with any metallic and other parts that can not be
separated.
Packaging
Aluminium packaging waste is a large short term source of scrap. Most of the products used in
food packaging have a lifetime of less than one year. The current consumption is close to 5 Mt
per year. The sector contributes nearly 28 % of recycled aluminium, second after the
transportation sector. For used beverage cans alone, the collection rates are as high as 80 to
93 % in some European countries (the Benelux, Scandinavian countries and Switzerland). The
mean collection rate of aluminium beverage cans in Western Europe, which has been monitored
since 1991, has almost tripled from 21 % in 1991 to 57.7 % in 2006.
Cable and wire
When buildings and installations are demolished, renewed and/or upgraded, scrap is generated.
However, no data is available to estimate a total amount. Since the current demand is mainly
driven by new installations in developing countries, the available scrap from this sector may be
expected to rise in future. According to Bureau of International Recycling (BIR), in 1997
worldwide, cables generated over one million tonnes of scrap metal, the majority being copper,
although high voltage power transmission cable uses aluminium as the conducting metal.
Electrical and electronic equipment (EEE)
EEE includes a wide range of complex products: large household appliances (refrigerators,
washing machines, stoves); small household appliances (vacuum cleaners, toasters, hair dryers);
information and telecommunications equipment (computers and peripherals, cell phones,
calculators); consumer equipment (radios, TVs, stereos); lighting (fluorescent lamps, sodium
lamps); electrical and electronic tools (drills, saws, sewing machines); toys, leisure, and sports
equipment (electric trains, video games); medical devices (ventilators, cardiology and radiology
equipment); monitoring instruments (smoke detectors, thermostats, control panels); automatic
dispensers (appliances that deliver hot drinks, etc).
It is estimated that each EU citizen currently produces around 17 20 kg per year of waste from
electrical and electronic equipment (WEEE) which adds up to 9 million 10 million tonnes at
the Community level. Expected growth rates are between 3 and 5 % each year. This means that
in five years time, 16 28 % more WEEE will be generated and in 12 years the amount is
expected to double. This rapid growth rate is due to the fast pace of technological development,
especially in information technology which has resulted in the more frequent replacement of
electrical and electronic equipment by industry.
In Europe, the average estimated composition of aluminium in WEEE is approximately 4.7 %.
The amount of aluminium scrap from e-waste can thus be estimated around 400000 tonnes per
year in the EU. However, the collection rate is unknown, and the actual amount of scrap
recovered is expected to be less.

Analysis

Construction and building

In some countries, especially those without an automobile industry, the building and
construction sector is probably the largest market for aluminium, consuming some 2 and 9 Mt
of aluminium products per year in Europe and the world respectively. However, it may vary
considerably from country to country due to the level and type of sector activities. The total
stored aluminium product in the sector is the largest since the start of the industrial application
of aluminium, amounting to nearly 170 Mt worldwide. However, as already mentioned, due to
the very long lifetime of buildings, its contribution to recycled scrap was only 7 % in 2004, i.e.
around 0.5 Mt in total.
The main use of aluminium in this sector is to provide materials for roofing and cladding, and
window and door frames, as well as small size applications such as shutters, door handles,
ceiling partitions, etc. The collection rate of aluminium scrap from building deconstruction and
demolition in six European countries has been shown to be between 92 and 98 % even though
the aluminium content in building (by mass) is below 1 %. While the collection of the small
sized items depends largely on the demolition method, the large sized items are often collected
separately to be sold directly for reuse or sent to a recycling plant.
Another way to classify scrap sources is according to waste categories. Waste which contains
aluminium scrap is likely to be classified in one of the categories according to the European
Waste List that are included in Table 1.

Analysis
Table 1:

Examples of waste categories according to the European Waste List that may
contain aluminium scrap.

Waste from agriculture, horticulture, aquaculture, forestry, hunting and fishing

02 01 10 waste metal
Waste from shaping and physical and mechanical surface treatment of metals and plastics
12 01 03 non-ferrous metal filings and turnings
12 01 04 non-ferrous metal dust and particles
12 01 17 waste blasting material other than those mentioned in 12 01 16
12 01 21 spent grinding bodies and grinding materials other than those mentioned in 12 01 20
12 01 99 waste not otherwise specified
Packaging (including separately collected municipal packaging waste)
15 01 04 metallic packaging
15 01 05 composite packaging
15 01 06 mixed packaging
End-of-life vehicles from different means of transport (including off-road machinery) and wastes from
dismantling of end-of-waste vehicles and vehicle maintenance (except 13, 14, 16 06 and 16 08)
16 01 03 end-of-life tyres
16 01 04* end-of-life vehicles
16 01 06 end-of-life vehicles, containing neither liquids nor other hazardous components
16 01 16 tanks for liquefied gas
Waste from electrical and electronic equipment
16 02 10* discarded equipment containing or contaminated by PCBs other than those mentioned in 16 02 09
16 02 11* discarded equipment containing chlorofluorocarbons, HCFC, HFC
16 02 13* discarded equipment containing hazardous components other than those mentioned in 16 02 09 to
16 02 12
16 02 14 discarded equipment other than those mentioned in 16 02 09 to 16 02 13
16 02 16 components removed from discarded equipment other than those mentioned in 16 02 15
Construction and demolition waste, metals (including their alloys)
17 04 02 aluminium
17 04 07 mixed metals
17 04 11 cables other than those mentioned in 17 04 10
Waste from waste management facilities, off-site waste water treatment plants and the preparation of
water intended for human consumption and water for industrial use (waste from incineration or
pyrolysis of waste)
19 01 12 bottom ash and slag other than those mentioned in 19 01 11
Waste from shredding of metal-containing waste
19 10 02 non-ferrous metals
19 10 06 other fractions than those mentioned in 19 10 05
Waste from the mechanical treatment of waste (for example sorting, crushing, compacting,
pelletising) not otherwise specified
19 12 03 non-ferrous metals
19 12 11 other wastes including mixtures of materials from mechanical treatment of waste containing
dangerous substances
19 12 12 other wastes including mixtures of materials from mechanical treatment of waste other than those
mentioned in 19 12 11
Municipal waste (household waste and similar commercial, industrial and institutional wastes)
including separately collected fractions
20 01 23* discarded equipment containing chlorofluorocarbons
20 01 35* discarded electrical and electronic equipment other than those mentioned in 20 01 21 and 20 01 23
containing hazardous components
20 01 36 discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20 01 23 and
20 01 35
20 01 40 industrial and institutional waste, metals
Other municipal waste
20 03 07 bulky waste
10

Analysis

1.2 Secondary aluminium production

Secondary aluminium scrap is treated by refiners or remelters. Remelters accept only new scrap
metal or efficiently sorted old scrap whose composition is relatively known. Refiners can work
with all types of scrap as their process includes refinement of the metal to remove unwanted
impurities (BIR, Report on the environmental benefits of recycling, 2008).
Old and new scraps are processed prior to melting by methods that depend on any
contamination that may be present. Aluminium turnings are usually contaminated with oil,
water and iron. They are therefore washed and dried to remove oil and water and then
magnetically processed to remove iron. Aluminium beverage cans are processed to remove the
lacquer coating that would otherwise lead to an increase in fume emission during melting.
Several melting processes are used depending on the scrap quality.
Clean, uncoated scrap can be melted in a reverberatory furnace; finely divided scrap, such as
turnings, are ideally melted in a coreless induction furnace; contaminated lower grades of scrap
are melted under a flux cover in a rotary furnace and aluminium components contaminated with
other metals such as steel bolts can be melted in a sloping hearth furnace.
The wrought remelts take good quality old and new scrap and convert this into extrusion billet
or rolling slab, usually of the same alloy. Good examples are the conversion of old and new
extrusion scrap into billet for extrusion production, and used aluminium beverage cans into
rolling slab for the production of more aluminium beverage cans.

1.3 Recycling processes

In general, aluminium scrap recycling consists of collection, sorting, shredding and/or sizing,
media separation and final melting at the refineries/remelters. Some scrap is already very clean
when collected but other scrap needs various treatment steps to be fit for use in the re-melting
process. This process can be summarised as the following:

Scrap metal is collected either separately or mixed and then sorted in the scrap yard and
then sold to scrap treatment plants or sent directly to a refiner/remelter.

Arriving at the scrap treatment plant, different types of metals are further separated and
prepared for shredding/sizing. Shredding and sizing is often needed for a further stage of
separation. First, while shredding and cutting, magnetic separation is used to single out
the ferrous metal. Then, using several media separation technologies, the non-ferrous
metal is separated first from non-metal elements and then different non-ferrous metals are
separated.

If shredded scrap metal is wet or dirty, it needs to be dried or to be further cleaned of

possible contaminants such as oil, grease, lubricants, lacquers, rubber, and plastic
laminates.
At the aluminium refinery, scrap metal is first cleaned, if necessary, from contaminants at below
melting temperature in kilns and then charged to the furnace going through melting,
fluxing/refining, and tapping.
Although not all the origins of scrap are included here, it is believed that their treatment process
resembles those that are described in Figure 2.

11

Analysis

Shredder
Shredder
Media
Media

End-of-life vehicles:
Today in the EU when a passenger car (as main
example for end-of-life vehicles) reaches its end of
life, it is brought to a specific collection point, which
in some cases could also be a generic scrap treatment
plant. ELVs are treated (depolluted) according to a
certain procedure guided by the ELV Directive, as
shown in the diagram. ELVs are first decontaminated
by removing various fluids and parts. The rest of the
car, including the body, the interior, etc. is fed into a
shredder. In the shredding process, magnetic
separation is used to remove the magnetic ferrous
fraction, leaving non-ferrous metals and non-metallic
materials to pass to further stages, i.e. dense media
separation and eddy-current separator, for the
segregation of one type from another. The separated
ferrous part contains as much as 98 % metal. More
than 99 % of the non-ferrous metal can be recovered.
Further advanced technology for the separation of
alloys is being developed for industrial applications.
To a certain extent, other recyclable fractions such as
glass and plastics are also recovered at this stage.
There are two main types of residue generated in
these processes: the airborne dust (fluff) caught by the
shredder dust collection system (consisting of
upholstery fibres, dirt, rust, paint, etc.) and the nonmetallic residues separated from the recovered
material streams by the media separation plant
(consisting of unusable rubbers, plastics, stones, etc.).

Figure 2:

An example of metal treatment.

The dust and the separated residues together usually represent about 17 to 25 % of the weight of
an average vehicle. In the past, they have been landfilled, representing no more than 0.2 % of
total landfill waste in the EU. However, with the implementation of the ELV Directive, which
requires 85 % (increasing to 95 % in 2015) of an ELV to be re-used, recycled, or recovered,
these residues are progressively being reduced.
Whilst sink-float separation is shown here in the diagram, where typically a ferrosilicon
suspension is used to achieve the separation of materials of differing densities, followed by a
washing stage, new alternative dry technologies are being developed using a variety of sensors
and separation techniques.
Used beverage cans
In most countries, used beverage cans (UBCs) are made both from steel and aluminium and
they are collected by local authorities as part of the municipal solid waste, although
increasingly, industry is involved in the collection of the UBCs. For example, in the UK, there
are separate containers for UBCs deposit, as well as special collection points for bringing in
UBCs which can be sold on a weight basis. At the collection point, steel cans are separated from
aluminium cans, baled and then sent to refineries.

12

Analysis

On arrival at the refinery, the baled aluminium can is first shredded into small-sized pieces, and
is then passed through a magnetic field to remove any remaining steel contaminants. Next, the
shreds need to be cleaned of paint, ink, coating, etc. by blowing in hot air at a temperature of
500 C. After the decoater, the shreds are fed into melting furnaces. At this stage, salt is usually
added to remove the impurities and to improve the quality of the product. The molten
aluminium is then cast into ingots.
Cables and wires
Demolition and civil engineering companies are the collectors of used cables and wires, which
may be directly sold to a scrap treatment plant or to a scrap trader. There are many different
types of cable. Outside power distribution uses aluminium core cable and most other type of
cables used in building, communication, electronics and automotive normally use copper core.
In general, cable and wire covered with thick plastic coating (often PVC) is not directly suitable
for feeding to a melting furnace due to the plastic to metal ratio.
According to BIR, the predominant way of recovering the metal from cable scrap in developed
countries is by automated cable chopping. Most cable chopping plants process only copper
cable scrap, a few plants process aluminium cable scrap, and some operate both a line for
aluminium and another for copper cable scrap.
The following steps are common in cable scrap chopping process:

Pre-sorting: to separate cable scrap by type of insulation, by conductor diameter, etc. and
to prepare it for feeding into the shredder. Pre-sorting also includes sorting copper from
aluminium-containing cable and removing unsuitable cables before entering the
automatic chopping system. As shown in the picture, pre-sorting can already result in
fairly clean scrap. The pre-sorting allows the maximum value for the recovered metal
scrap to be obtained and makes further separation of plastics easier.
Cable chopping: usually desirable for processing long cable sections. It is the first step in
reducing the size of the cable. Compared to shredding, cable chopping produces little, if
any, filter dust.
Granulation: carried out twice so that the cable chops are of a sufficiently fine size to
ensure that most of the insulation is liberated from the cable. Inevitably however, small
amounts of metal remain embedded in the plastic.
Screening: to enhance the recovery of metal, some chopping lines also use vibrating
screen to yield the desired chop size. The smaller the chop size is, the more efficient the
removal of the metal.
Density separation: similar-sized chop fractions that collect on the screens are discharged
and fed to an air table being fluidised and separated into two fractions: clean metal
products and essentially metal-free tailings. Generally, middling fractions are
reprocessed again in the system or can be re-tabled.

The metal content of residue streams can vary from less than 1 % to more than 15 %. If a dry
electrostatic system is used, the metal content may be reduced to less than 0.1 %, which will
consequently increase the value of the recovered plastic.
An example is the cable scrap, which is usually a mixture of copper or aluminium conductors
with rubber, plastic or paper insulation. They may also have steel or lead armouring. Pre-sorting
in such a case is very difficult.
Electronics and electrical equipment
This waste stream covers a wide variety of end-of-life products mainly from households and
offices. The WEEE Directive defines the responsibility of producers in recycling and waste
prevention; however, users and local authorities play an essential role in waste collection and
separation. The WEEE Directive also requires that hazardous components, such as batteries,
printed circuit boards, liquid crystal displays, etc. be removed with proper technologies. This is
13

Analysis

done at different stages of the treatment process depending on the implementation of the
Directive in Member States.
After de-pollution, WEEE consists chiefly of a mixture of metal, plastics and glass. From here,
the treatment of WEEE in general has the following steps, though the process may vary with
different combinations of: shredding, granulating (more than once), magnetic separation, and
eddy current separation (more than once), there is also the possibility of density separation on
the separation table and/or hand separation (Figure 3).

Figure 3:

An example of WEEE treatment.

The stainless steel, aluminium and copper fractions are separated from other ferrous metal and
other non-ferrous metal during these processes and can be sent directly to the steelworks or
refineries. The metal content in the plastic could be high; however it is possible to further
recover these metals later during the plastic recycling process or, if the plastic is incinerated,
from the bottom ash of the incinerators.
Scrap metal from construction and demolition
Regulation and standards related to construction and demolition have been developed in the past
years mostly in favour of selective demolition, which has been proven to be most effective for
recycling various types of waste streams. For cost reasons, metal scrap is separated whenever
possible along the dismantling process and is sold for direct reuse or to traders or treatment
plants. Since by weight aluminium and steel have different prices, further separation is often
performed on site.

1.4 Industry structure

The aluminium scrap recycling industry consists of scrap collection and sorting, distribution,
treatment and processing (Figure 4). Along this recycling chain, scrap is cleaned to become
secondary material for final metal production. Secondary aluminium production can be clearly
distinguished from primary aluminium production.

14

Analysis

Refining
Remelting

Figure 4:

The inverted pyramid structure of the recycling sector.

Depending on the type of product and the country, the collection system can vary. Large-sized
and quantity end-of-life products, such as those from construction and demolition, are usually
transported directly to the scrap yard or scrap treatment plants. Both ELVs and WEEE place the
responsibility of recycling, hence scrap collection, on the producers. Small products such as
packaging materials are collected by the local authorities, which means that in this case,
collection is not in the hands of the scrap metal industry, though some industry initiatives are
taken in the case of UBCs, e.g. collection centre, scrap terminals, where aluminium cans are
separated and baled for transportation to treatment plants or refineries.
EUROSTAT 2006 waste statistics recognise 50 682 recycling installations in the EU-27, of
these the metal recycling federations estimate some 40000 will deal with aluminium. There are
307 shredders in the EU-27 and downstream media separation plants and most of them will
have an output of shredded aluminium scrap. The secondary aluminium processors, i.e. refiners
and remelters, are mostly small and medium in size and, according to EAA/OEA, there are 123
refining plants and the same number of remelting plants in Europe in 2009.

1.5 Economy and market

Aluminium scrap is recycled or reused whenever possible. According to EAA, in 2004
worldwide around 16 Mt of aluminium scrap were recycled annually, more than half of which
were old scrap. The rest of the old scrap generated, about 7 Mt, was not registered statistically,
however, it was expected that more than 50 % would be recycled and only a small amount of
un-recoverable scrap would be landfilled. This was partly due to limitations of current treatment
techniques.
The production of recycled aluminium and aluminium casting from 2003 until 2007 is shown in
Table 2.

15

Analysis
Table 2:

Production of recycled aluminium and aluminium casting from 2003 to 2007 in

Europe (in 1000 tonnes).
Stream

2003

2004

2005

2006

2007

Recycled aluminium
(1)(2)

2283.7

2264.3

2796.7

2882.4

3175.9

Aluminium castings
(2)

2273.8

2491.3

2365.9

2124.3

1943.1

Since 2007 EU-27.

(1) Recycled aluminium mainly includes aluminium casting alloys and
deox. aluminium.
(2) Partially estimated.

Table 3 shows that in 2007 in the EU-15 there were 133 refiners producing casting alloys and
deoxidation aluminium and 107 remelters producing wrought alloys in the shape of extrusion
billets and rolling slabs, with the number of employees amounting to approximately 10000.
Table 3:

Structure of the EU-15 refiners (Situation as of 2007).

Production
>100 000 t
up to 100 000 t
up to 50 000 t
up to 40 000 t
up to 20 000 t
up to 10 000 t
<5 000 t
Total

Germany
3
3
2
3
1
1
1
14

Italy
1
3
1
3
5
7
17
37

UK

Spain

1
1
6
10
6
24

3
5
4
16
28

France
2
1
2
3
3
6
17

Europe
4
9
10
8
26
29
47
133

Scrap trade within the EU as well as import and export to other countries has been established
for decades. The amount of aluminium scrap (new and old) shipped within Europe was
estimated being 5 Mt in 2004. According to EUROSTAT (intrastat and extrastat), the import
and export in 2008 is shown in Table 4.

16

Analysis
Table 4:

Intrastat and extrastat aluminium scrap figures in tonnes for each of the EU-27
member states in 2008.
COUNTRY
AUSTRIA
BELGIUM
BULGARIA
CYPRUS
CZECH
REPUBLIC
DENMARK
ESTONIA
FINLAND
FRANCE
GERMANY
GREECE
HUNGARY
IRELAND
ITALY
LATVIA
LITHUANIA
LUXEMBOURG
MALTA
NETHERLANDS
POLAND
PORTUGAL
ROMANIA
SLOVAKIA
SLOVENIA
SPAIN
SWEDEN
UNITED
KINGDOM
TOTAL

EU-27_EXTRA
IMPORT
EXPORT
23722
1929
9091
41501
52
1518

EU-27_INTRA
IMPORT
EXPORT
73244
143101
111328
0
544
1
2892

931

190

57493

59007

1424
124
25
11677
79186
22573
4920
132
74108
213
647
19473

4491
13587
19898

20287
2398
8371
17491
78448
4763
37
3543
9744
1165
1835
1885
530
68217
296
388
1863
0
3077
4489
18738

69302
361
21953
183344
464652
6388
51426
2
303337
7464
1286
103933
1
166220
67156
2321
262
4638
19403
87810
20228

36440
17496
28974
324705
624291
8499
22060
17497
46469
3038
3510
9278
912
194067
123172
39587
14157
10109
8813
104783
87843

37341

759792

110531

113235

359098

1052495

1892613

2085950

35038
20
89
336

In last few years, before the financial crisis, the demand for scrap rose worldwide. The
collection rate of non-ferrous metals increased in all sectors in the EU. In the second half of
2008, with the onset of the global financial and economic crisis, falling output among many
metal processing companies has resulted in low levels of demand for scrap; many consumers
have announced plant closures, production curtailments or reductions of employee working
hours. The price of aluminium scrap decreased by half compared to spring 2008 (see Figure 5).
However at the end of 2009 prices were still comparable to aluminium scrap prices in 2005.
Prices recuperated somewhat in early 2009.

17

Analysis
Old casting scrap and secondary aluminium alloy price development
Source: Verband Deutscher Metallhnder e.V., 2004-2008, Metal Bulletin, 2004-2008

2500

2000

1500

1000

500
Secondary alloy (DIN226/A380)

LME Cash

January
February
March
April
May
June
July
August
September
October
November
December
January
February
March
April
May
June
July
August
September
October
November
December
January
February
March
April
May
June
July
August
September
Oktober
November
Dezember
January
February
March
April
May
June
July
August
September
Oktober
November
Dezember
January
February
March
April
May
June
July
August
September
Oktober
November
Dezember

Old casting scrap

0

2004

Figure 5:

2005

2006

2007

2008

Prices of aluminium scrap from 2004 to 2008.

1.6 Specifications and standards

Currently, specifications and standard classifications for metal scrap exist at all levels,
international, European, national, as well as between individual parties. It is clear that for the
reason of marketing and trading, standards and specifications are needed not only to set the
price but also to be used as a reference for classification and quality control. In many cases
based on the production need, scrap is processed according to the bilateral specifications agreed
upon between the scrap processor and smelters and refiners.
Traded scrap metal is basically classified according to several properties, most notably:

chemical composition of metals

level of impurity elements
physical size and shape
homogeneity, i.e. the variation within the given specification.

European Standard EN 13920 on aluminium and aluminium alloy scrap

The EN standard covers all types of aluminium scrap and provides the norm for scrap
classification. The summarised standards are described in Annex 1.
ISRI specifications
Developed by the USA Trade Association, the Institute of Scrap Recycling Industries (ISRI),
this American specification classifies the following: non-ferrous Scrap, ferrous scrap, glass
cullet, paper stock, plastic scrap, electronics scrap, tyre scrap; and is used internationally. The
ISRI specification for aluminium scrap is shown in Annex 2.
National association specifications
Many trade associations in Member States have developed their own specifications for
aluminium scrap over many years. Generally these national specifications have been agreed
upon between scrap processors and the aluminium refiners and remelters in their respective
Member States.
Bilateral contract/specification
As already mentioned, there are also specifications made as agreements or contracts in trade
between two parties. Such specifications are usually based on a standard classification with
additional requirements suitable for the desired production process or product. In this case, the
specifications are being continuously reviewed and, if necessary, modified.
18

Analysis

1.7 Legislation and regulation

In the EU the management of waste scrap metal is currently under the waste regulations, e.g. the
Waste Framework Directive and EU Waste Shipment Regulation.
Scrap treatment plants (e.g. shredders, dismantlers, media separation plants) as well as scrap
collectors and sorting plants are operated under a permit for waste treatment, although the
details of their permits vary across member states.
The production of secondary aluminium and the associated treatment of scrap metal on site are
subject to the IPPC Directive. The current discussion on the possible extension of the scope of
Directive 2008/1/EC of the European Parliament and of the Council of 15 January 2008
concerning integrated pollution prevention and control (the IPPC Directive) in relation to waste
treatment activities has suggested the inclusion of separate installations for scrap metal
treatment.
Certain metal-containing waste streams are regulated under specific directives, such as the
WEEE, the ELV Directive and the Directive on packaging and packaging waste. In these
directives, the following elements regarding the treatment and processing of the types of waste
are described and they ensure the proper handling of the waste stream:

The WEEE Directive includes compliance with minimum standards for recycling and
treatment;
The ELV Directive includes minimum technical requirements for the treatment.

Waste shipment
On 12 July 2007, Regulation (EC) No 1013/2006 (the new Waste Shipment Regulation) came
into force. Accordingly, most metal scrap is under the List B of Part 1 of Annex V (also referred
to as the green list), which are not covered by Article 1(1) (a) of the Basel Convention, and
therefore are not covered by the export prohibition.
Export of waste under the green list within the OECD countries is not subject to notification
and consent procedure and is done under normal commercial transactions; however, the new
Waste Regulation does require the completion of an Annex VII form.
For green list exports to non-OECD countries, the regulations require the Commission to
obtain a new declaration from the receiving country as to whether it will accept each kind of
waste; it may also require pre-notification.
In List B, the possibly affected wastes are some metal scrap under B1010 (ferrous and
aluminium) GC010 (electronic assemblies consisting of only metals or alloys) and GC020
(electronic scrap, e.g. printed circuit boards, electronic components, wire) and reclaimed
electronic components suitable for base and precious metal recovery). However, some of the
non-OECD countries failed to respond and where no reply is received, those countries are to be
regarded as having chosen a procedure of prior written notification and consent. Default
controls of prior written notification and consent are applied.
When scrap is traded under the procedure of prior notification and consent, exporters of scrap
metals to non-OECD countries are required to pre-notify, which requires administration and
payment of a fee as well as the establishment of a financial guarantee(1).
In any case, the Waste Shipment Regulation allows exports from the Community only if the
facility that receives the waste (i.e. the secondary metal/steel production plant) is operated in
accordance with human health and environmental standards that are broadly equivalent to
standards established in Community legislation (IPPC).
(1) A financial guarantee is not required in cases of shipment of green listed waste to EU Member States with
transitional provisions to control such waste under the Amber control procedure.

19

Analysis

Shipments of waste (e.g. waste metals) exceeding the limit values of radioactivity defined by
the EC Directive 2006/117/Euratom, which refers to the concentration limits in Directive
96/29/Euratom, require the appropriate regulatory approvals in accordance with the radiation
protection legislation and fall outside the scope of the Waste Shipment Regulation. However,
scrap showing radioactivity below the thresholds of the radiation protection legislation fall
within the scope of the Waste Shipment Regulation No. 1013/2006. Most Member States
classify low radioactive waste as unlisted waste requiring notification, arguing that there is an
increased risk associated with the waste.
The end-of-waste will affect metal scrap that has fulfilled the criteria and become
product/secondary material in such a way that the trading will be not under the waste shipment
regime. The impact on waste shipment is described in Chapter 3.
By-products
If a certain metal scrap generated, for example by the metal processing industry, were regarded
as being a by-product, and not being waste, as defined by Article 5 of the WFD, then 'end-ofwaste criteria' would not apply unless the by-product were later to become waste.
Article 5 of the WFD on by-product reads as follows:
1.

A substance or object, resulting from a production process, the primary aim of which is
not the production of that item, may be regarded as not being waste referred to in point
(1) of Article 3 but as being a by product only if the following conditions are met:
a. further use of the substance or object is certain;
b. the substance or object can be used directly without any further processing other than
normal industrial practice;
c. the substance or object is produced as an integral part of a production process; and
d. further use is lawful, i.e. the substance or object fulfils all relevant product,
environmental and health protection requirements for the specific use and will not
lead to overall adverse environmental or human health impacts.

2.

On the basis of the conditions laid down in paragraph 1, measures may be adopted to
determine the criteria to be met for specific substances or objects to be regarded as a byproduct and not as waste referred to in point (1) of Article 3. Those measures, designed to
amend non-essential elements of this Directive by supplementing it, shall be adopted in
accordance with the regulatory procedure with scrutiny referred to in Article 39(2).

What is noteworthy is that Article 5 of the WFD says may be regarded, which appears to
leave a certain freedom of choice even if the four conditions of Article 5 are met, at least as long
as measures under Article 5.2 have not been adopted.
REACH
When metal scrap ceases to be waste, it becomes subject to the provisions of the REACH
Regulation. The implications of this are discussed in detail in Chapter 3.

1.8 Environmental and health aspects

Energy use and GHG emissions
The production of secondary aluminium is estimated to consume 5 7 GJ per tonne due to the
improvement in recent years and the average total emission is about 350 kg of CO2 emission per
tonne of metal production. It has been reported that the production of one tonne of aluminium
from scrap requires only 7 % of the energy required for primary production (excluding bauxite
production).

20

Analysis

Other air emissions

Dust and air emissions from scrap processing are generally at a low level. However, emissions
of hazardous air pollutants may be generated by the secondary metal production in a furnace,
e.g. dioxins and furans, metals/metal oxides. In the EU such emissions are controlled according
to permits under the IPPC directive. Emissions from furnaces are being managed by process
control and special flue-gas treatment.
Risks related to scrap transportation and storage
Scrap metal in itself does not pose any risk to the environment, i.e. there are no environmental
risks in the transportation and storage of the metal itself. There is also no convincing evidence
of substantial leaching from coated or painted aluminium scrap metal. However, if metals are
contaminated with oil or mixed with other wastes, this may create hazards in relation to
transportation or storage. For example, oil or any other liquid attached to scrap metal, when
exposed to rain, may cause contamination to its surrounding environment.
Coatings and paints
Coatings can be divided into organic coatings (powders, pastes, liquids, film or sheeting),
inorganic coatings (manufactured from ceramics and cement mortar) and metallic coatings.
The mechanical handling of scrap and scrap processing removes some coatings as an effect of
the processing. In the case of shredding scrap metal, the processing in the hammer mill removes
most of the paint/coatings from the metal except for zinc coatings which remain mainly on scrap
fragments after shredding. The removed paint/coatings are separated from the scrap metal and
are collected into the shredder residue.
Some processes have a specific decoating step. Residual paint/coatings are removed in the metal
works as part of the process, either contributing to slag generation or air emissions. PVC and
other halogenated coatings may contribute to the generation of dioxins and furans. However, a
link on the composition of the input materials and the emissions of these substances has not
been demonstrated. The emissions are determined by the process and by treatment of the fluegas.
Radioactive metal scrap
Scrap metal can contain sources of radiation with the associated environmental and health risks.
Higher levels of radiation are possible and may stem from losses, accidents or the inadvertent
disposal of radioactive materials.
Radioactive scrap metal can occur in a number of different ways. Some of the main origins are
the demolition or decommissioning of industrial facilities processing raw materials containing
naturally-occurring radionuclides, the decommissioning of nuclear installations (such as nuclear
power plants and other nuclear fuel cycle facilities) and other facilities, loss of sources (sealed
radioactive sources are sometimes lost or mislaid and they may be collected as scrap metal),
demolition of facilities in which radioactive sources have been used, incorporation of old
radioactive devices into scrap (items such as timepieces and compasses covered with
radioluminous paint, lightning rods, thoriated lenses, etc. may be collected as scrap).
In order to minimise the risks, radioactivity needs to be measured systematically. The United
Nations Economic Commission for Europe (UNECE) has released recommendations to monitor
and reduce the risks involving radioactivity in scrap metal. While these recommendations are
not legally binding, they provide guidance based on existing best practice to all interested
parties (scrap yards, metal smelters, customs, regulatory authorities and transporters, amongst
others).

21

End-of-waste criteria

END-OF-WASTE CRITERIA

2.1 Rationale for end-of-waste criteria

The end-of-waste criteria should be such that the material has waste status if - and only if
regulatory controls under waste legislation are needed to protect the environment and human
health; otherwise the material should have end-of-waste status to facilitate recycling and
recovery. The criteria should be developed in compliance with the legal conditions, should be
operational, should not create new disproportionate burdens and should reflect that aluminium
scrap recycling to be a well-functioning industrial practice today.
The main types of benefits that can be expected when EU-wide end-of-waste criteria for
aluminium scrap are introduced are given below:

Improved functioning of the internal market (simplified and harmonised rules across
countries).
Clearer differentiation between high quality scrap and low-quality scrap. Only high
quality scrap will cease to be waste.
Reduction of administrative burdens especially related to shipment and transport.

2.2 Conditions for end-of-waste criteria

According to the Waste Framework Directive, Article 6, certain specified waste shall cease to
be waste within the meaning of point (1) of Article 3 when it has undergone a recovery
operation and complies with specific criteria to be developed in accordance with the following
conditions:
a.
b.
c.
d.

The substance or object is commonly used for a specific purpose;

A market or demand exists for such a substance or object;
The substance or object fulfils the technical requirements for the specific purpose
referred to in (a) and meets the existing legislation and standards applicable to products;
and
The use of the substance or object will not lead to overall adverse environmental or
human health impacts.

Regarding the first two conditions, it is evident in the case of aluminium scrap that a structured
market exists (e.g. there are classifications of scrap metal used for trading). Aluminium scrap is
commonly used as a feedstock in re-melting and refining to produce new aluminium (secondary
aluminium). There is generally a demand by the aluminium industry for scrap that complies
with specification or standard such as the 'EN 13920' and any other use than for the production
of new aluminium is highly unlikely. This is also true in the case of exports from the EU,
including to non-OECD countries.
The third condition implies that end-of-waste criteria need to ensure that, at the point of ceasing
to be waste, any technical requirement related to use are fulfilled and the recycled material
comply with applicable legislation and standards as product. In the case of aluminium scrap,
this means that at the moment of end-of-waste, the scrap should fulfil standards/specifications
that the secondary aluminium industry uses for the scrap it buys.
From a life cycle point of view, aluminium scrap metal recycling as such has overall
environmental benefits (especially the energy related air emissions). The use of scrap metal in
the furnace is regulated as far as emissions are concerned by the IPPC Directive regardless of
whether the scrap is a waste or not. Also, outside the EU, process emission control of secondary
metal production does not depend on the waste status of the scrap.

23

End-of-waste criteria

The main areas where the waste status of aluminium scrap can potentially make a difference for
the environmental and health impacts is transport and trade (waste shipment). If scrap has endof-waste status, it can in principle be transported by any transport undertaking and not only
those that are permitted to transport waste. It is important that only scrap without waste-specific
hazardous properties cease to be waste.
Regarding waste shipment, it is important that only scrap for which it is highly likely that it will
actually be used for secondary metal production be exported and imported outside waste
regulatory controls (waste shipment regulation). It is therefore also important regarding the
fourth condition that the scrap be processed to comply with the standards and specifications of
the scrap-using industry so that a demand by the metal industry effectively exists.

2.3 Outline of end-of-waste criteria

According to the JRC methodology guidelines, the ultimate aim of end-of-waste criteria is
product quality and end-of-waste criteria will therefore usually include direct product quality
requirements. In addition, a set of end-of-waste criteria may include elements that check product
quality indirectly, in particular requirements on input materials and requirements on processes
and techniques. Usually, there will also be supportive requirements on quality assurance and
regarding the provision of information (e.g. on product properties).
The TWG confirmed the appropriateness of this approach for the case of aluminium scrap and
that the approach of combining different types of requirements in a set of end-of-waste criteria
corresponds well to the good industrial practice of ensuring the product quality of the scrap. The
TWG also supported the view that the existing recycling system should not be disturbed by endof-waste criteria for aluminium scrap. There should be a clear identification where scrap has
attained a quality that is sufficient to ensure that no environmental risks occur when scrap is
transported, further processed or traded without being controlled as waste.
During the workshop in July 2009 and by other input, many experts stressed the need to keep
the criteria clear, as simple as possible, and enforceable. It was suggested to reinforce the role of
the direct product quality requirements, in particular to provide criteria that are useful in the
case of spot checks of traded material and which would allow demonstrating non-compliance
with the end-of-waste criteria directly. As already proposed in earlier papers, the direct product
requirements should address certain direct hazards for the environment and human health such
as related to radioactivity and oil content. In addition, strong support was widely given to the
concept of a general quantitative criterion, such as a limit on metal content, content of foreign
materials or metal yield, that would serve as a check for the completeness of treatment and as a
check that the metal is sufficiently pure for safe use. All types of aluminium scrap would have
to meet this limit value in order to benefit from end-of-waste status.
Quality assurance was another element of the end-of-waste criteria that the technical working
group considered as especially important and useful because it is needed to establish sufficient
confidence in the end-of-waste status.
At the same time, the discussions of the TWG showed that the requirements on input materials
and treatment processes should mainly address and be stringent regarding those materials that
pose a specific hazard if not treated adequately. Since the use and treatment of waste which
contains non-hazardous metals to produce aluminium scrap was less of a concern; many experts
suggested that the end-of-waste criteria could be less specific regarding these aspects.
The different possible elements of the end-of-waste criteria, the main considerations made by
the TWG and the resulting proposals are discussed in the subsequent sections and are
summarised in Annex 3.

24

End-of-waste criteria

2.4 Criteria on product quality

Product quality criteria are needed to check for direct environmental and health risks and if the
product is suitable as direct input to the final uses (refinery/foundry). They also should allow for
deciding if the metal in the scrap is sufficiently pure and has been separated effectively from
other types of materials.
Limit on metal yield, metal content or content of foreign materials
A limit on metal yield, metal content or the content of foreign materials needs to be proposed in
order to determine directly if the separate collection and/or treatment of the waste has been
effective in producing a scrap which is sufficiently pure. Such a limit value would also restrict
the possibilities of having other wastes mixed with the scrap.
A limit value on metal yield, metal content or non-metallic components can be used in
compliance testing by the producer of end-of-waste scrap (at the site of the processor) as well as
in on-the-spot checks, for example by regulatory authorities.
For the sake of clarity, the same limit value should apply to all types/categories of aluminium
scrap. (Stricter requirements in specifications, standards and commercial agreements for specific
types of scrap will of course be possible.)
Bellow all three types of limit values are discussed, although not all of the options should
ultimately be included in the end-of-waste criteria.
Definition of foreign materials
Foreign materials include:

metals other than aluminium and aluminium alloys

non-metallic materials such as earth, dust, insulation and glass
combustible non-metallic materials such as rubber, plastic, fabric, wood and other
chemical or organic substances
larger pieces (brick-size) which are non-conductors of electricity such as tyres, pipes
filled with cement, wood or concrete.

The definition of foreign materials could be similar to that of steriles (as defined in the case of
iron and steel scrap). Steriles are defined in the European Steel Scrap Specification as nonferrous metals, non-metallic materials, combustible non-metallic materials, larger pieces (bricksize) which are non-conductors of electricity such as tyres, pipes filled with cement, wood or
concrete and by-products arising from steel melting, heating, surface conditioning, grinding,
sawing, welding and torch cutting operations, such as slag, mill scale, baghouse dust, grinder
dust, sludge). In case of aluminium scrap, for some grades, other metals are desired to some
extent in order to produce the desired quality of aluminium alloy except for ferrous metals and
lead.
Limits for foreign materials are not generally defined, however some categories of EN 13920
include equivalent limits in the range from 2 5 %. A summary of limitations on foreign
materials is shown in Table 5.

25

End-of-waste criteria
Table 5:

13920-3
13920-4
13920-5
13920-6
13920-7
13920-9
13920-10
13920-11
13920-12

13920-13

13920-15

Summary of the EN 13920 limits on foreign materials.

The scrap shall be free from attachment devices, steel core wires, coiling spools of any material,
bundling material and other components of electric lines other than aluminium cables and wires.
The scrap shall not be coated and shall be free from burned wire, oil, grease, dust, plastics and any
other type of foreign material.
The scrap shall be free from oil, grease, powder, plastics and any other type of foreign material.
The scrap shall not contain more than 5 % (mass fraction) of oil, grease, dust, plastics and any
other type of foreign non-metallic material as a total. The scrap shall be free from foreign metallic
materials.
The scrap shall not contain more than 5 % (mass fraction) of oil, grease, dust, plastics, calcareous
deposits and any other type of foreign non-metallic material as a total. The scrap shall be free
from pieces of alloys of the 2xxx or 7xxx series and free from foreign metallic materials.
The percentage of volatile substances shall not exceed 2 % (mass fraction). The total percentage
of other non-metallic foreign material shall not exceed 2 % (mass fraction). The total percentage
of foreign metallic material, either free or attached, shall not exceed 2 % (mass fraction).
The sum of the percentages of oil, grease and other non-metallic materials in the scrap shall not
exceed 2 % (mass fraction). The scrap shall be free from metallic foreign materials.
The scrap shall not contain more than 2 % (mass fraction) of moisture and not more than 5 %
(mass fraction) of total volatile substances. The scrap shall be free from any other foreign
material, e.g. free iron and lead, and shall exclusively consist of beverage cans. It shall be free
from burnt or oxidized cans and aluminium foil.
The scrap shall consist of non-oxidized pieces free from moisture, oil, grease, dust, plastic, iron,
brass and any other foreign material.
The scrap shall be unoxidized and the following tolerances apply to the delivered mass: 0.5 %
(mass fraction) of magnetic iron, 5 % (mass fraction) of moisture and oil, 3 % (mass fraction) of
fines passing through a 20 mesh sieve (0.71 mm opening), after drying. The scrap shall not
contain any other foreign materials.
The scrap shall be unoxidized and the following tolerances apply to the delivered mass: 0.5 %
(mass fraction) of magnetic iron, 5 % (mass fraction) of moisture and oil, 3 % (mass fraction) of
fines passing through a 20 mesh sieve (0.71 mm opening), after drying. The scrap shall not
contain any other foreign materials.
The scrap shall not contain free iron. The scrap shall not be heavily oxidized by the adopted
decoating process. The scrap shall not contain fines less than 1mm in size and shall be free from
non-metallic materials.

The analysis of the content of foreign materials would have to be based on manual sorting of
non-metallic objects and particles. In the case of very fine particles (e.g. from WEEE), the
analysis by hand sorting may not be practically possible, therefore an alternative could be to
determine the metal yield. The metal yield analysis should be according to EN 13920-1:2002,
which is summarised and clarified below:
1.
2.
3.
4.

removal and determination of moisture (according to 7.1. of the EN 13920-1:2002)

removal and determination of free iron (according to 7.2. of the EN 13920-1:2002)
determination of the metal yield (according to 7.3. of the EN 13920-1:2002)
the metal yield shall be calculated as a mass after melt (m4) and the mass after
determining the moisture content (m2), according to Equation 1.
m [%] =(m4/m2) 100

26

[1]

End-of-waste criteria
Mass (m1)
(aluminium scrap sample input)

Mass (m2)
(after drying at 105oC and 360oC)

Mass (m3)
(after removal of free iron)

Mass (m4)
(after melting)

Definition of metal content

In the case of aluminium scrap, metal content would include metals other than aluminium. The
reason for not excluding other metals is that they are in some cases desired when scrap is used
for aluminium production. Oxides generated by 'normal' oxidation of macroscopic aluminium
would also be included. Dust should, however, not be counted towards the metal content
because it is undesired and will usually not contain much metallic aluminium.
The analysis of the metal content would have to be based on the manual sorting of metallic and
non-metallic objects and particles. Non-metallic material adhering to metal objects would have
to be detached. The smaller the objects or particles, the more difficult such an analytical
procedure would be.
A limit on metal content is not proposed in the EN standard. Experts suggested metal content
limits in the range 90 98 % and a limit of 95 % is considered ambitious yet realistic.
Definition of metal yield
The metal yield is defined under EN 13920-1:2002 and can be measured by melting small
amounts of fine metal scrap in a laboratory furnace using a crucible.
The metal yield is usually lower than the metal content due to the other impurities being
included in the metal scrap (e.g. oxide, fine dirt attached to the scrap). The metal yield
according to standard EN 13920 varies from 80 90 % (except category 13920-14 scrap from
post-consumer aluminium packaging and 13920-16 scrap consisting of skimmings, drosses,
spills and metallic which have a lower metal yield). Based on the consultation with experts from
the technical working group, a metal yield limit value of 90 % could be considered equivalent to
a metal content limit value of 95 %.
Choice of parameter for the limit value
The proposal here is to set both a limit value for foreign materials and a limit value for metal
yield, whereby it will be sufficient to comply with one of the two limit values. The owner of the
aluminium scrap that applies the end-of-waste status would be allowed to choose if compliance
is by metal yield or content of foreign materials. In order to establish clarity for inspections by
authorities, the owner would have to declare which of the two parameters chosen.
The reason for this proposal is the practical feasibility of the measurement/testing.

27

End-of-waste criteria

Metal yield can be measured well for smaller particles or objects but it can be very hard or
practically impossible to obtain a representative laboratory sample from a mixture of large
objects.
Measuring foreign materials makes sense for larger objects that can be manually separated
without disproportionate efforts but makes less sense for smaller particles. It also has to be
considered that non-metallic materials adhering to the surface would potentially be much more
relevant for smaller particles.
It is proposed not to set a limit value on the metal content because the concept of foreign
materials as well as the value of the metal yield is already used by European standards EN
13920. The concept and measurement of foreign materials is practically equivalent to the
reverse of the concept of metal content. However, for metal content it is conceptually slightly
more complex than for foreign materials and therefore should be considered a second choice.
Furthermore, the scrap shall not contain excessive oxide in any form, except for typical amounts
arising from the outside storage of prepared scrap under normal atmospheric conditions. This
requirement is used in order to avoid the inclusion of metal scrap which will have a very low
economic value due to the excessive metals oxidation.
Draft formulation of the requirement:
The total amount of foreign materials shall be 5 % by weight or the metal yield shall be 90 %;
Foreign materials include:

metals other than aluminium and aluminium alloys

non-metallic materials such as earth, dust, insulation and glass
combustible non-metallic materials such as rubber, plastic, fabric, wood and other chemical or
organic substances
larger pieces (brick-size) which are non-conductors of electricity such as tyres, pipes filled with
cement, wood or concrete.

The scrap shall not contain excessive metal oxide in any form, except for typical amounts arising
from the outside storage of prepared scrap under normal atmospheric conditions.

Oil, oily emulsions, grease and lubricants

Oil, oily emulsions, grease or lubricants are often used in products made of aluminium and for
the working of these materials. If they are present in scrap, except negligible amounts, they
present a direct environmental risk to water and soil, especially if not handled with protective
measures during transport and storage. In larger amounts, they are also undesired in the
aluminium production process.
The discussion of the TWG during the workshop in July 2009 in Seville led to the conclusion
that a qualitative requirement was sufficient in the sense that the aluminium scrap should be free
of visible oil. This means that oil, oily emulsions, grease, or lubricants in general should not be
visible in any part of the scrap load with special attention to the bottom of the scrap load where
the oil can be accumulated. Each load/consignment of scrap should be inspected visually
regarding this requirement, especially in those parts of the load where oil is most likely to
accumulate (the bottom).
An additional proposal of some of the TWG experts was to use the formulation of 'dripping oil'
instead of 'visible oil'. However, the criterion on dripping oil could cause confusion and would
require extra analysis. Another disadvantage is the increased environmental risk caused by a
higher content of oil compared to the definition of 'visible oil'. In order to guarantee the
appropriate quality of scrap without a negative environmental impact, 'visible oil' is the
preferable formulation.

28

End-of-waste criteria
Draft formulation of the requirement:
Scrap must be free of visible oil, oily emulsion, grease or lubricants.
Oil, oily emulsions, lubricants or grease should not be visible in any part of the scrap load, except
negligible amounts that will not lead to any dripping. Visual inspection shall pay particular attention to
those parts of the load where oil is most likely (the bottom).

Radioactivity
The end-of-waste criteria need to address radioactivity because of the direct environmental and
health risks of incidents involving radioactive scrap. In addition, the financial consequences of
such incidents for the metal processing industry are always very serious, and the incidents can
lead to a loss of trust in the recycled metal industry and the associated products due to
unnecessary radiation emanating from consumer purchases.
It is very important to detect the presence of radioactive material as early as possible in the
supply chain and scrap with end-of-waste status must not show any detectable radioactivity
above background level ('background level' as defined in UNECE recommendations).
All scrap grades shall be checked as early as possible, preferably at the origin of the material
source when scrap enters the material chain, and in all subsequent stages of the scrap supply
chain, in strict compliance with state-of-the-art and most efficient detection equipment and
within the limitations of accessibility.
The technical working group strongly supported that the monitoring of aluminium scrap with
respect to radioactivity should be carried out in accordance with the UNECE Recommendations
on Monitoring and Response Procedures for Radioactive Metal Scrap(2) and that the scrap metal
should show no detectable radioactivity above background level.
More specifically, the radiation of each load of metal scrap shall be monitored in accordance
with the UNECE Recommendations and no radiation levels significantly in excess of natural
radiation background in the local area shall be detected. This should be demonstrated by the
owner of the scrap metal that declares compliance with the end-of-waste criteria, for example by
providing a Radioactivity Test Certificate in accordance with the UNECE Recommendations.
The test certificate has to be issued (or stamped) by the operator of the detection equipment,
which needs to be a reliable and qualified organisation/company.
More information on the UNECE Recommendations:
The recommendations (or Protocol) were agreed upon after the second meeting of the Group
of Experts on the Monitoring of Radioactive Scrap Metal held in June 2006 under the auspices
of the UNECE.
The recommendations are intended to assist Governments, industry and all concerned parties to
counter the problem of radioactively contaminated scrap metal, activated scrap metal and scrap
metal with radioactive source(s) or substances contained within it (termed 'radioactive scrap
metal' []) by seeking to prevent its occurrence, by effectively monitoring metal shipments and
facilities, and by intercepting and managing any radioactive scrap metal that is detected. The
recommendations set out the responsibilities of all concerned parties and the actions required of
them to fulfil the objectives.
The owner or seller of the material that applies the end-of-waste criteria should arrange for
radiation monitoring to be performed on the scrap metal (each load or consignment) and to
provide a certificate indicating the results of that monitoring. (An example of a certificate of
shipment monitoring is attached as Annex 1 to the UNECE Recommendations.) The
owner/seller should ensure appropriate training of involved staff.

(2) http://www.unece.org/trans/radiation/docs/recommendations_e.pdf

29

End-of-waste criteria

The recommendations also contain specific recommendations regarding radiation monitoring at

scrap yards, processing facilities and melting plants, including that the owners of major scrap
yards, processing facilities and melting plants should carry out the measures listed below.

Ensure that incoming and outgoing shipments are checked by administrative and visual
means.
Provide radiation monitors at the entrance/exit to the premises and, as appropriate, on
conveyors and grapples. All entrances and exits should be monitored.
Ensure the effectiveness of the radiation monitors by appropriate quality assurance
procedures to verify the ability to detect changes in radiation intensity.
Arrange for periodic calibration and testing of the detectors (at least annually) to ensure
optimum performance.
Provide appropriate training in radiation monitoring and initial response procedures for
personnel likely to be involved in the monitoring of scrap metal shipments.
Establish a response plan for action in the event of radioactive material being discovered.
Make a formal arrangement with the national organisation with experience in radiation
monitoring and radiation protection to provide:

training of personnel on radiation detection and response procedures, and

assistance in the event of a radiation incident involving the detection of radioactive
scrap metal.

Require that contracts for the supply of scrap metal include the condition that any cost
associated with radioactive material discovered in shipments be accepted by the seller
unless the original owner of the radioactive source or material can be found.

Instruments for detecting radioactive material can be divided into three categories and any of
them could be used for measuring radioactivity:

Pocket-type instruments, which are small, lightweight instruments used to detect the
presence of radioactive material and to inform the user about radiation levels.
Hand-held instruments, which usually have greater sensitivity and can be used to detect,
locate or (for some types of instruments) identify radioactive material. Such instruments
may also be useful for making more accurate dose rate measurements in order to
determine radiation safety requirements.
Fixed, installed, automatic instruments, which are designed to be used at checkpoints.
Such instruments can provide high sensitivity monitoring of a continuous flow of vehicles
whilst minimising interference with the flow of traffic.

Draft formulation of the requirement:

The following must be excluded: material presenting radioactivity in excess of the ambient level of
radioactivity; and radioactive material in sealed containers, even if no significant exterior
radioactivity is detectable due to shielding or due to the position of the sealed source in the scrap
delivery.
The following must be fulfilled:

To demonstrate that the scrap has been checked, each consignment/shipment of scrap shall
be accompanied by a completed certificate according to Annex I of the 2006 UNECE
Recommendations on Monitoring and Response Procedures for Radioactive Scrap Metal or
an equivalent certificate according to national rules) (3)
This certificate shall be issued by the operator of the detection equipment.

(3) The certificate may be included in other documentation accompanying the consignment/shipment.

30

End-of-waste criteria
Certificates may be provided in electronic form. For multiple shipments to the same customer, and with
the agreement of the customer, a single certificate may be supplied to demonstrate that all loads have
been monitored.

Hazardous properties
Condition (d) of Article 6 of the WFD demands that end-of-waste criteria need to ensure that the
use (understood here as including also transport, handling, trade) of scrap shall not lead to
overall adverse environmental or human health impact.
This implies that aluminium scrap should not obtain end-of-waste status if it has any of the
hazardous properties included in Annex III of the WFD (properties of waste which render it
hazardous).It is understood for example that asbestos should not be included in end-of-waste
scrap.
The reason is that in this case, general waste regulatory controls as well as the specific
provisions of the WFD on hazardous waste (in particular Articles 17 to19 regarding control, ban
on the mixing and labelling of hazardous waste) are needed to protect the environment and
human health.
Comprehensive direct monitoring of the 'product' regarding all of the possible hazardous
properties by specific tests is, however, not a feasible approach. The best approach to exclude
hazardous properties of the product, is to rely on a combination of requirements on input
materials, treatment processes and techniques, and quality assurance. (These requirements are
presented in the following sections further below.)
Nevertheless, it has been suggested to also include in the product quality requirement a clause
that clearly establishes that scrap with hazardous properties does not cease to be waste. This is
needed not only to establish clarity in principle but has also a practical value in cases when
certain types of hazardous properties are detected as part of a visual inspection, especially when
hazardous criteria are further harmonised within the EU (e.g. ecotoxicity, leachate criteria).
A particular aspect that should also be addressed is pressurised, closed or insufficiently open
containers of all origins. Such containers represent a specific hazard because they could cause
explosions in the metalwork furnace. This hazard is not addressed explicitly by Annex III of the
WFD. A specific clause would therefore have to be included in the end-of-waste criteria.
Draft formulation of the requirement:
The scrap does not have any of the properties included in Annex III of the Directive 2008/98/EC of
the European Parliament and of the Council on waste (properties of waste which render it
hazardous). Properties of individual metal elements included in aluminium alloys are, however, not
relevant for this requirement.
The scrap does not contain any pressurised, closed or insufficiently open containers of any origin
that could cause explosions in a furnace.

Grading according to a standard or specification

Grading according to a standard or specification is needed to demonstrate that the scrap fulfils
the technical requirements for a specific purpose and it also indicates that there will be a market
and demand.
The relevant standards or industry specifications are those for direct input to one of the final
uses (the production of metal substances or objects by smelters/refinery/foundries). The
standards or specifications used may be of an agreed upon nature across an industry sector (e.g.
EN 13920, ISRI) or may be defined by one or more individual final use companies.
The TWG has advised against demanding strict compliance with a closed list of grades,
standards or specifications. Reasons are that the specifications are a matter of commercial
transaction rather than a regulatory means and that the monitoring would be very burdensome
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End-of-waste criteria

and that the details of specifications are very greatly, for example across countries and
individual user firms.
The TWG also advised against obliging the metal scrap supplier to produce proof that the
graded scrap will actually be accepted by a user (e.g. by systematically producing commercial
contracts). This was deemed too burdensome and disproportionate.
However it is considered proportional and useful to demand a grading according to a
specification and standard that can be freely chosen as long as the specification or standard is
one that is actually used by a user to define the needs for scrap input materials. For each
consignment of aluminium scrap the supplier should assign a grade (or category) according to
an 'authentic' user specification or standard. The identification of the specification should be
sufficiently clear so that it will be possible for the competent authorities, in the case of an
inspection, to verify by own investigation that the specification corresponds to authentic user
requirements.
The scrap categories of the EN 13920:2002 (except EN 13920-14, 13920-16), the ISRI
classifications or classifications used for aluminium product will generally be acceptable.
Draft formulation of the requirement:
The scrap shall be graded according to a customer specification, a standard or an industry
specification for direct input to one of the final uses (the production of aluminium or aluminium
alloy, as material or object, by remelting/refining).
The specifications used may be of an agreed upon nature across an industry sector (e.g. EN 13920,
ISRI specification) or may be defined by one or more individual final use companies.

Coatings, paints, plastics

Only small amounts of organic paints, coatings and other organic substances can be tolerated for
secondary aluminium production. Generally, plastics are covered under the definition of foreign
materials. However, there is a particular concern that PVC and other halogenated substances
may lead to higher emissions of dioxins and other toxic substances from the furnaces. An extra
limitation on PVC would therefore be indicated to minimise the environmental impact.
Draft formulation of the requirement:
The scrap shall not contain PVC.

Considerations leading to the omission of proposals of separate product quality

requirements
Requirements on chemical composition
The technical working group advised against including requirements regarding the chemical
composition (other ferrous or non-ferrous metals such as steel, copper, zinc, etc.). This was
deemed a matter for commercial agreements rather than for regulation because no particular
environmental or market risks were to be addressed.
Dimension
According to the EN 13920 the scrap shall not contain objects of a dimension that does not fit
into a metalwork furnace (i.e. generally not greater than 600mm 600mm 400mm). The
dimension is related to the technical limitation of the process and does not have a direct effect
on environmental or health issues. Therefore, the size limitation need not be included as one of
the criteria and can remain a matter for the specifications and commercial agreements between
the seller and buyer.

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End-of-waste criteria

2.5 Criteria on input materials

The purpose of criteria on input materials is to check product quality indirectly.
The end-of-waste criteria should allow as input only waste types for which it is practical to
obtain aluminium scrap in compliance with the product quality requirements. This implies that a
waste can only be allowed if it contains aluminium metals that can be recovered for the
production of new aluminium products and, after appropriate treatment, can be used without
overall adverse environmental or human health impacts.
The discussion in the TWG showed that the criteria on input materials should not be
unnecessarily restrictive and that, in principle, all types of waste that contain recoverable
aluminium scrap and for which treatments exist to obtain scrap metal with the required product
quality should be allowed as input. The technical working group suggested that the criteria on
input materials and treatment processes be explicit for those wastes that pose relevant hazards
and that the criteria be more general for other types of wastes.
It was pointed out during the discussion with the TWG, that an approach based on a 'positive
list' of allowed waste input materials held the risk of 'omitting' suitable wastes, or excluding
waste which becomes suitable as new treatments become available. It was also pointed out that
assigning a waste to a category under the European Waste List per se does not give any
guarantees on the nature and suitability of that waste. (The waste categories listed in Table 1 are
examples of wastes which may contain metal that can be recovered.) Basing the criteria on a
negative list of unsuitable input materials would imply a high risk of 'forgetting' to exclude
unsuitable waste types. However, it should be clear that no mixing with other wastes (i.e. wastes
that do not contain recoverable aluminium) are allowed.
These considerations suggest that regarding non-hazardous waste, it would be sufficient to
include a general requirement that they must contain recoverable aluminium. Regarding
hazardous wastes, the points below need to be considered in addition.
Hazardous wastes pose substantial risks to the environment and human health. Waste law
includes specific regulatory controls to deal with these risks. A hazardous waste can only cease
to be waste if it can be established that it has been treated in a way that reliably removes all
hazardous properties.
The monitoring and testing of product quality alone is not a workable approach to ensure that
the resulting product does not have any hazardous properties as sufficient confidence could only
be obtained with disproportionate testing efforts. Instead, the monitoring of product quality
should be complemented by controlling that whenever a hazardous waste is used as an input, it
has undergone a suitable treatment. Which type of treatment is suitable depends on the type of
hazardous waste used as input.
As part of end-of-waste criteria, the choice of suitable treatment to deal with hazardous waste
cannot be left open to case-by-case industry decisions but must follow clearly defined and
legitimated treatment requirements for the specific type of hazardous waste. In the EU, such
treatment requirements have been established in the ELV Directive and the WEEE Directive.
Hazardous wastes that are covered by the provisions of one of these Directives could therefore
be allowed as input materials.
If discarded equipment containing chlorofluorocarbons is considered a hazardous waste only
due to the content of chlorofluorocarbons, they can be rendered non-hazardous by removing
these substances in a controlled process. This is a clearly defined process that can be included in
the process requirements. This type of hazardous waste may therefore also be allowed as input
material.

33

End-of-waste criteria

Further types of hazardous waste could be allowed as input at a later stage if their treatment is
legally regulated in an equivalent manner.
An alternative approach, which would prevent the need for updates of the end-of-waste criteria,
would be to generally allow hazardous waste as input material under the condition that proof be
provided and approved by the authorities (for example as part of the permit for the waste
treatment facility) that suitable treatment has been applied to remove all hazardous properties.
Filings and turnings
Aluminium turnings usually contain oil, even when such a material is treated by centrifuging or
pressing (to remove the oil). During transport and storage, the turnings will oxidise relatively
quickly. However, not allowing filings and turnings to reach end-of-waste status would exclude
a quantitatively important type of scrap from this mechanism and introduce a certain
fragmentation in the metal scrap market. Altogether there is no clear technical conclusion as to
whether filings and turnings are suitable input materials for a scrap to reach end-of-waste status.
Draft formulation of requirements:
No other waste shall have been used as input to obtain the scrap than wastes that contained
recoverable aluminium at source.
No hazardous waste shall have been used as input to obtain the scrap except:

wastes that are covered by the WEEE Directive or the ELV Directive; and
discarded equipment containing chlorofluorocarbons that does not have any hazardous
properties except those due to the chlorofluorocarbon content;
other hazardous waste for which proof is provided that suitable treatment to remove all
hazardous properties has been applied in a treatment process which is approved by
authorities.

2.6 Criteria on treatment processes and techniques

The purpose of the criteria on treatment processes is to check product quality indirectly.
When reaching end-of-waste status, the material must have gone through all necessary treatment
processes that make it suitable as direct input material for the final users of scrap and allow for
transporting, handling, trading and using the scrap without increased environmental and health
impacts or risks.
The required treatment processes to achieve this differ depending on the waste types from which
the scrap has originally been obtained. Some details on the treatment processes and techniques
for different types of waste are described in Chapter 1.3.
The metal scrap case study in the JRC End-of-Waste Criteria report suggested process
requirements according to the three groups of scrap sources, however further considerations
showed that the system of grouping is not essential in order to propose the criteria.
Instead, the criteria on processes and techniques can include:

basic general process requirements that apply in all cases (for all types of waste);
specific process requirements for specific types of waste (including all allowed hazardous
waste types).

This reflects the discussions in the technical working group, which showed that for nonhazardous waste, there is a preference for generic requirements that do not prescribe a specific
technology. The reason is that industry should not be prevented from adapting to the specific
circumstances or from innovation. Specific process requirements are however needed for the
34

End-of-waste criteria

treatment of hazardous wastes and certain complex waste and possibly also for certain special
cases of input materials (such as turnings or cables) for which the direct product requirements
are considered not stringent enough.
The general process requirements clarify the minimum treatment required and where in the
treatment chain the point of end-of-waste is reached. The principle is that scrap should have
completed all requirement treatment that makes it suitable for direct use in the production of
new metal. Excepted from this are only pre-treatments that normally take place directly at the
refiner/remelter. Some scrap may be obtained in pure form by segregating it from other waste at
source or during collection. Any other wastes (that at the origin contain aluminium scrap and
other material) must have been treated to separate the non-metal and if needed also other metals.
ELV and WEEE are complex wastes for which treatment requirements have been established by
European Directives. The wastes covered by these Directives, whether hazardous or nonhazardous, can not cease to be waste unless they have fulfilled the provisions of the Directives.
Specific treatment requirements are also needed for discarded equipment containing
chlorofluorocarbons because they are hazardous waste and not in all cases covered by the
requirements of the ELV or WEEE Directives.
If filings and turnings are allowed as input materials, special treatment requirements are needed
for the removal of cutting fluids such as oil because the related qualitative product quality
requirement alone may not be stringent enough for this particular kind of waste.
Requirements of how to treat cables and containers can be seen as optional as a reinforcement of
the set of criteria. To some extent, the relevant issues are already addressed by the product
quality requirements.
There was a broad consensus in the technical working group that there should be no
requirements on baling or compacting, as this might be counterproductive (e.g. hiding of bad
material inside bales).
Draft formulation of requirements:
The aluminium scrap shall have been segregated at the source or while collecting and shall have
been kept separate; or the input wastes shall have been treated to separate the aluminium scrap
from the non-metal and undesired metal components.
All mechanical treatment (like cutting, shearing, shredding or granulating; sorting, separation,
cleaning, de-polluting, emptying) needed to prepare the material for direct input into final use shall
have been completed.
Specific requirements include the following:

a.
b.
c.
d.
e.
f.

Input materials that originate from end-of-life vehicles or waste electronic or electric
equipment shall have completed all treatments as required by the ELV Directive (Article 6)
and the WEEE Directive (Article 6).
Discarded equipment containing chlorofluorocarbons (CFCs) must have been captured in an
approved process.
Filings and turnings that contain cutting fluids such as oils shall have been treated to remove
these fluids by processes like centrifugation or pressing.
Cables must have been stripped or granulated. If a cable contains organic coatings (plastics),
the organic coatings must have been removed according to the best available techniques.
Barrels and containers including inter alia oil and paint drums, shall have been emptied and
cleaned.
Hazardous substances shall have been efficiently removed.

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End-of-waste criteria

Information provided with the product

The owner of the material that invokes the end-of-waste status must provide information about
the product to characterise the product technically, produce a radioactivity test certificate as
required by the end-of-waste criteria, identify the external verifier of the quality assurance
system (see below) and certify that all end-waste criteria have been met and accepted by buyers
and competent authorities. Such information may also be provided electronically.
Draft formulation of requirements:
Each consignment of the aluminium scrap or multiple loads to the same customer shall either be
accompanied by the following information or be available in electronic form to the customer and
upon the request of any competent authority:

a.
b.
c.
d.
e.

the name or code of the scrap category according to a specific product standard or
specification and a declaration of compliance with the standard or specification;
a radioactivity test certificate in accordance with the UNECE Recommendations on
Monitoring and Response Procedures for Radioactive Scrap Metal or similar certificate
according to national rules;
identification of the external verifier or the certification of the quality assurance system;
statement of conformity to the end-of-waste criteria;
whether or not the scrap complies with the limit for foreign materials or metal yield.

2.7 Quality assurance

The technical working group has expressed very strong support for making quality assurance
requirements part of the end-of-waste criteria. This is needed to create confidence in the end-ofwaste status. The owner of the material applying the end-of-waste status will have to rely on a
quality assurance system to be able to demonstrate compliance with all the end-of-waste criteria
for the material to cease to be waste.
A quality management system must be in place and cover the key areas of operation where
compliance with end-of-waste criteria will have to be demonstrated.
Whilst the implementation of an internationally recognised quality management such as ISO
9001 would be suitable, it is not considered appropriate for end-of-waste criteria to specify a
particular quality management system which must be implemented.
It is considered appropriate and proportional for the end-of-waste criteria to require that a
quality management system be implemented and externally verified. Such verification should
assess if the quality management system is suitable for the purpose of demonstrating
compliance with the end-of-waste criteria applicable to the case in question.
A suitable quality management system for scrap metal is expected to include:

36

procedures for deciding about the acceptance of input materials

monitoring of processes to ensure they are effective at all times
procedures for monitoring product quality (including sampling and analysis) that are
adjusted to the process and product specifics according to good practice
procedures that ensure the effectiveness of the radiation monitoring and the ability of the
radiation monitors to detect changes in radiation intensity
actively soliciting feedback from customers in order to confirm compliance with product
documentation
record keeping of main quality control parameters
measures for the review and improvement of the quality management system
training of staff.

End-of-waste criteria

The competent waste authority must be able to commission an independent second party audit
of the implemented quality management system to satisfy itself that the system is suitable for
the purpose of demonstrating compliance with end-of-waste criteria.
The detail on the verification, auditing or inspection of the quality assurance system can follow
different national approaches.
Draft formulation of requirements:
The acceptance of input materials, all treatment steps and product quality checks (including any
sampling and testing or visual inspections) according to the end-of-waste criteria must be carried
out under a fully implemented and externally verified quality management system.
The quality management system must at least include the following elements:

1.

the quality management system must be auditable and ready for inspection by the competent
authority under waste law to ensure that the system is suitable for the purpose of
demonstrating compliance with end-of-waste criteria;
must include a set of documented procedures addressing each key process relevant to
compliance with the technical end-of-waste criteria, including:

2.
a.
b.
c.
d.
e.
f.
g.
h.

acceptance of input materials;

monitoring of processes to ensure they are effective at all times;
monitoring product quality (including sampling and analysis) that are adjusted to the
process and product specifics according to good practice;
procedures that ensure the effectiveness of the radiation monitoring and the ability of the
radiation monitors to detect changes in radiation intensity
actively soliciting feedback from customers in order to confirm compliance with product
documentation;
record keeping of main quality control parameters;
measures for review and improvement of the quality management system;
training of staff.

Specific requirements regarding Point 2.c (monitoring product quality)

It must be assured that each consignment shall at least be:

monitored for radioactivity;

inspected visually regarding all other product quality requirements.

By means of representative sampling of consignments the monitoring shall also include testing of
compliance with the limit value regarding the foreign materials or the metal yield.
The appropriate frequencies of sampling shall be established by consideration of the following factors:

the expected pattern of variability (for example as shown by historical results);

the inherent risk of variability in raw material input quality and any subsequent processing;
the inherent precision of the monitoring method;
the proximity of actual results to the limit of compliance with the relevant end-of-waste
condition.

The process of determining monitoring frequencies should be documented as part of the overall quality
assurance scheme and as such should be available for auditing.

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End-of-waste criteria

2.8 Application of end-of-waste criteria

For the application of end-of-waste criteria laid out above, it is understood that a consignment
of aluminium scrap ceases to be waste when the owner of the scrap certifies that all of the endof-waste criteria have been met.
It is also understood that aluminium scrap that does not meet the end-of-waste criteria can still
be used for the production of secondary aluminium. In this case, the recycling or recovery is
completed when the scrap is melted in a furnace and new metal has been produced. The new
metal will not be considered waste.
The end-of-waste criteria including proposed systems of monitoring with explanations are
summarised in Annex 3.

38

Impacts

IMPACTS

In order to evaluate the soundness of end-of-waste criteria developed for scrap, it is necessary to
assess the possible impacts of removing the waste status from these materials. The impact
assessment covers environmental, economic and legal impacts that may result once the scrap
ceases to be waste. Many Member States have different operational rules and permits used for
waste handling. As a result, since there are different existing approaches, the impact of end-ofwaste would be different from country to country.

3.1 Environmental and health impacts

Energy use and GHG emissions
When the end-of-waste criteria facilitate more recycling of aluminium scrap, this will imply
savings in energy use and GHG emissions associated with aluminium production. It is however
not possible to calculate the size of this effect.
Other air emissions in scrap treatment
The treatment of metal scrap will remain covered under waste regulations and the specific air
emissions and dust created during the treatment of metal scrap are unlikely to be changed by
introducing the end-of-waste criteria.
Also the specific air emission from the aluminium production in the EU are not expected to
change because the relevant processes and flue-gas treatments (under IPPC permits) will not be
affected.
It is unlikely that facilitated export of end-of-waste scrap outside the EU would have any
substantial effect on air emissions of aluminium production outside the EU. Because of the strict
product quality requirements, it can be expected that exported end-of-waste scrap will on
average not be more polluted than the scrap used today for aluminium production outside the
EU (notably the possible amounts of coatings present will be very limited by the limit value on
foreign materials/metal yield and PVC limitation). An increase in air emissions should therefore
not be expected.
Risks related to scrap transportation and storage
Storage and transport of end-of-waste scrap will no longer be covered by waste regulatory
controls. Theoretically this could imply an increased risk for the environment if the end-ofwaste scrap had properties that would need such controls and if waste regulation were effective
in providing it. There are however only moderate risks associated with end-of-waste scrap,
mainly related to (invisible) residual oil. Normal good practice of transport and storage seem to
be appropriate to control these types of risks and in most cases waste regulatory controls would
not lead to additional measures to further reduce these risks. (In practice it can be expected that
metal scrap as a product will in most cases be stored under the same conditions as it used to be
as waste).
Radioactive metal scrap
The end-of-waste criteria include strict requirements on radioactivity monitoring which are
likely to improve the risk control related to radioactive metal scrap.

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Impacts

3.2 Economic impacts

The economic and market impacts are expected mainly due to the:

avoidance of costs related to the shipment of waste;

benefits of harmonisation of waste status for end-of-waste criteria;
avoidance of costs of handling the scrap in terms of permits and licenses;
REACH compliance (see separate section 3.3.).

Shipment
The waste status of metal scrap affects the exportability by increasing the administrative and
economic burdens. The costs to the recycling sector in the wider sense are higher under the
waste regime. The total involved costs related to international shipment are difficult to estimate,
however the European Ferrous Recovery and Recycling Association (EFR) and The British
Metals Recycling Association (BMRA) gave practical examples of possible complications due
to the 'waste' status of scrap metal and these are given below.

Requirement to obtain certain information from overseas (non-EU) re-processors to

satisfy broad equivalence obligations set out in the Packaging Directive, WEEE
Directive and Waste Shipments Regulation.

With end-of-waste status, it would be possible to produce the necessary evidence based on the
end-of-waste criteria concept, rather than having to track the material through the docks and
across the world. According to one large UK metal recycling company, the costs in 2007
associated with obtaining this information from around 200 facilities was GBP 100 000. This
figure includes administrative and translation (of supporting documents/licences) costs.

Notification and insurance costs on financial guarantees for waste shipments sent to
countries where pre-notification is required (including certain green list shipments)
under the Waste Shipments Regulations.

Each notification requires a financial guarantee, except to countries under treaty of accession
arrangements. Several Dutch companies at one time have had a total of up to EUR 10 million
tied up in financial guarantees. This is financed by the bank at certain costs and also means a
lesser liquidity for the companies. Because of this there is a limit to the number of notifications
a company can handle/absorb. In other words, there is an artificial (trade) barrier and
companies can not sell to all potential customers after their financial limit has been reached.
Also in the UK, the cost of a single notifiable ship has been qualified as high, plus insurance
premiums on a financial guarantee (typically several thousand pounds).The shipment of green
listed wastes to EU Member States with transitional period do not require a financial guarantee
(insurance). However, administrative fees for notification might be high and vary from country
to country. End-of-waste would facilitate the free trade of scrap that meets the set end-of-waste
conditions and criteria where there are metal works in Latvia up to 31 December 2010; Poland
up to 31 December 2012; Slovakia up to 31 December 2011; Bulgaria up to 31 December 2014;
and Romania up to 31 December 2015.

Administration costs for maintaining Annex VII Waste Shipments Regulation tracking
forms and domestic waste movement forms.

In addition to the direct administration costs associated with form filling, there is an issue of
having to supply commercially sensitive data. The British Metals Steel Association received
evidence that companies have lost customers due to this requirement. Customers outside the EU
jurisdiction are not willing to have their commercial transactions recorded and made available to
public authorities. Therefore they turn to non-EU suppliers, such as exporters from the US,
Russia or Japan.

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Impacts

Loss of business where customers fail to provide appropriate information.

The Waste Shipment Regulations require that non-OECD countries reply to the Commissions
note verbale, indicating which wastes they are prepared to accept and what control
procedures they wish to apply. If they do not reply (and very many do not or give a negative
reply for waste from the EU, whilst they import scrap from elsewhere but do not consider such
metal scrap to be waste), then notification controls apply by default. In these circumstances,
either: the business incurs the additional costs of notification; or since notification
documentation from the receiving country is difficult and time-consuming to obtain, in the
meantime the buyer may turn to a non-EU supplier. On average the notification procedure takes
3 to 6 months. Where notifications are not required, the current waste status may still affect
exportability in terms of the waiting time for buyers to receive import licenses. As price and
demand change quickly, these waiting times lead to market distortions and inefficiency.
Evidence from published notifications show, despite the cost, that non-hazardous waste are
exported under such costly controls that were not originally intended to be applied to nonhazardous wastes at all. Industry absorbs the costs and regulatory relief is sought to reduce
costs.
A number of Member States allow waste to cross only at designated border crossings which
restricts transport routes. The recycling sector explained that it worked with the Council and
Commission Regulations (EC) No 1420/1999 and No 1547/1999 from 1998 to 2006 to obtain
well over a dozen amendments to keep recyclables flowing to customers in non-OECD
countries. However, due to the response or lack of response of certain non-OECD countries
those secondary metal markets are instead fed for example by the USA. However, comparison
of the exports of the USA (where scrap is not waste) with exports of the EU (where scrap is
waste), since there is a great overlap of the major trading partners, reinforces that the markets
will adjust and flows may change slightly, but no great market changes would be forecast on the
end-of-waste of the EU. Furthermore, end-of-waste criteria may not affect how importing
countries view EU-origin scrap. For example: the Chinese CCIC pre-inspections use their own
parameters to accept or refuse shipments regardless of EU terminology; and the Indian port
authorities inspect according to their own regulations.
It has also been mentioned that a number of Member States are now asking for pre-notification
for non-hazardous green list wastes, e.g. scrap shipments to other EU Member States.
Permits, licenses related to handling with metal scrap as waste
The situation for waste collectors and processors regarding permits or licenses will not change.
A relief is expected mainly for traders which will not need any waste licenses when they trade
only scrap which has ceased to be waste. The relief from the 'waste' status being for example in
the permits, licenses and administration are described below.
In a Waste Treatment Authorisation, a scrap company may have to complete the administration
paperwork indicated below every year:

An annual report (company-specific reporting of all transactions and EWC code-specific

reporting of all transactions). This usually requires administration time of 5 person
months/year).
Monthly reports of incoming and outgoing materials.
Record books.
Special activity license for the yard, for transport and for processing (for the yard
approval as an example the license renewal is every 10 years. The procedure takes at least
6 months to 1 year.) The costs of the reports are substantial.
Environmental impacts assessment of the scrap yard activity, if handling over 5
tonnes/day.
Environment responsibility insurance.
Waste transport authorisaion. (There is a restricted market of carriers, transporters of
scrap classified as waste.)
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Impacts

National laws implementing the Directive on ELV.

National laws implementing the Directive on WEEE.
National laws implementing the Directive 2006/66/EC of the European Parliament and of
the Council of 6 September 2006 on batteries and accumulators and waste batteries and
accumulators.

Most companies that are active in the export market have specialized staff for environmental
issues. The waste status/legislation is the main reason for this as well as the necessity for quality
management because of the strict legislation. On average, a staff will consist of 1 to 5 persons
depending on the size of the company. In the Netherlands such a staff will represent a cost of
anywhere between EUR 50 250 000 in costs. This can, however, be much higher for larger
companies.
The considered estimate of the administrative burden associated with the legislative
requirements of handling of scrap metal as a waste material may have had a cost in the region of
GBP 262 885 in 2008 for one major company in the EU.

3.3 Legal impacts

REACH
Article 2.2 of the REACH Regulation(4) specifies that waste is not a substance, mixture or
article within the meaning of Article 3 of this Regulation. As long as aluminium scrap has the
status of waste it is therefore not a substance, mixture or article for REACH and most
obligations under the REACH Regulation do not apply.
When aluminium scrap cease to be waste according to Article 6 of the WFD, the exemption
under Article 2.2 of the REACH Regulation no longer applies. A benefit of EU-wide end-ofwaste criteria will therefore be to clarify when aluminium scrap has to be considered a
substance, mixture or article under REACH and when not.
However, concerns have been raised that the end-of-waste criteria may lead to disproportionate
regulatory burdens under REACH, especially for the companies that produce aluminium scrap
with end-of-waste status. The main potential burdens are related to the registration of the
substances in end-of-waste scrap and to the obligations to provide safety information to
downstream users.
On 14 October 2009, the Commission organised a meeting in Brussels to discuss end-of-waste
criteria for iron and steel scrap and aluminium scrap and REACH. The meeting brought together
experts from European and national industry associations of all the affected sectors (metal
producers, processors and recyclers, as well as the waste management sector) and staff of DG
Environment, DG Enterprise and the Joint Research Centre (the IPTS). A draft version of this
chapter of the report was distributed to the participants in advance of the meeting and the
meeting allowed to further clarify the link between end-of-waste and REACH, which has been
taken into account in this chapter.
Mixtures, substances and impurities
The main reference regarding waste and recovered substances is the Commission document
CA/24/2008 rev.3, which was produced as a follow up to the Fifth Meeting of the Competent
Authorities for the implementation of Regulation (EC) 1907/2006 (REACH). The CA/24/2008
rev.3 document states the following regarding recovered metals:

(4) EC 1907/2006.

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Impacts

Under REACH, pure metal (even if containing a certain amount of impurities) is considered as
a substance. Recovered pure metal (even if containing a certain amount of impurities) is also a
substance. Registration requirements for the substance will depend on whether the substance
has been registered before and the relevant safety information is available (see Article 2 (7)(d))
of REACH.
Alloys are considered as (special) preparations(5) and the substances in those preparations are
subject to registration. Recovered metal made from mixed alloy metal scrap will normally be a
preparation but it could in certain cases also be a substance with impurities (e.g. when the
purpose of recovery is only to reclaim one main metal and all other constituents can be seen as
impurities). In general, all components which have been intentionally selected for recovery and
which have a main function in the recovered material should be seen as separate substances
(e.g. steel will next to iron normally always contain manganese; the recycled steel is therefore a
preparation). Constituents which only occasionally occur in parts of the waste from which the
recovered metal originates or which do not have a particular function in the recovered material
can be seen as impurities (e.g. molybdenum may occur in certain types of steel but not in
others).
The CA/24/2008 rev.3 document states the following on impurities (in general terms on waste
and recovered substances):
The guidance on substance identification defines an impurity as an unintended constituent
present in a substance as produced. It may originate from the starting materials or be the result
of secondary or incomplete reactions during the production process. While it is present in the
final substance it was not intentionally added.
Recovered substances may contain impurities which may distinguish them from corresponding
materials not deriving from recovery processes. This is in particular the case when recovered
materials contain unintended constituents which have no function for the recovered material
and the only reason for their presence in the recovered material is that they were part of the
input waste for the recovery process. The content and nature of such unintended constituents
may vary significantly from batch to batch (e.g. in time and location). Full knowledge of the
exact composition in each such case may require substantial analytical efforts. While such
constituents may have originally been intentionally added as substances to form a preparation,
their presence in the recovered material may be unintended (depending on whether these
constituents have a specific function or not) and therefore, they can be considered as impurities,
which do not require separate registration.
Constituents present in quantities above 20 %(w/w) should, however, in general not be
considered as impurities but as separate substances in a preparation. However, in the case that
recovered material is intentionally selected for the presence of certain constituent(s), those
constituents should also be considered to be separate substances, even if they are present in
smaller quantities than 20 %(w/w) (e.g. if PVC is selected for the presence of softeners, it may
be necessary to register these softeners, unless they have been registered before).
During the mechanical separation of mixed waste it is often impossible to reach 100 % purity
free of alien elements. These alien elements often are either extraneous to the waste stream per
se (for example, and depending on the waste stream, stones, plastics, pieces of rubber, sand,
etc.) or extraneous to the material object of the recovery but part of the final product that
became waste (for example, paints, coatings, etc.), of which the composition and total amount
are difficult to precise. After appropriate sorting and separation, these fractions should be
present in the recovered material only in very small fractions. In this case, such elements can be
considered as impurities that do not need to be registered.

(5) The term preparation has meanwhile been superseded by the term mixture.

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Impacts

Even if impurities do not have to be registered separately, they may be relevant for the hazard
profile as well as the classification and labelling of the substance or mixture in which they
occur. Relevant risk management measures may need to be recommended in SDS or
information according to Art. 32. These risk management measures can consist e.g. in further
purification steps to eliminate impurities or measures to ensure the safe handling of the
substance with the impurities in it.
Substances in aluminium scrap with end-of-waste status
Under REACH only substances are subject to registration. According to REACH, a recovered
metal may be as defined below:
1.

2.

A mono-constituent substance. The content of main metal must be [Me1] 80 %. This

substance may contain impurities, in principle below 20 % for the purposes of naming the
substance. The foreign materials (end-of-waste criteria <5 %) should be covered by
these 20 %. As mentioned in the guidance for substance identification (Section 4.2.1.2),
deviation from this 80 % rule (i.e. content below 80 %) has to be justified (e.g. it has the
same physicochemical properties and the same hazardous profile, the range of
concentration of the main constituent and the impurities overlap the 80 % criterion and
the main constituent is only occasionally 80 %).
A mixture. When the metal scrap is an alloy (special mixture of metals) or the metal scrap
is intentionally selected for the presence of several metals [Me1], [Me2], [Me3], .
mixtures are composed of two or more substances. In the particular case of scrap metals
the majority of substances, if not all, are metals. As in this case, each substance can bring
to the mixture a maximum of 20 % impurities and, thus, the theoretical maximum of
impurities should be 20 % (only in the case that each substance brings 20 % of impurities
in the mixture). However, in reality, the percentage of impurities would be less.

Note: Producers of scrap applying the end-of-waste status (as manufacturers) have the
obligation under REACH to decide which of the above two cases applies. This rather short
summary should not prevent recyclers from reading and using the guidance for substance
identification (available in ECHA web pages).
To understand which substances, as defined by REACH, there are in aluminium scrap with endof-waste status, the following technological aspects given below need to be considered.
Aluminium scrap with end-of-waste status would:
a.
b.
c.

always contain aluminium as a component that has been intentionally selected for
recovery and that has a main function in the recovered material.
sometimes contain other components that have been intentionally selected for recovery
and that have a main function in the recovered materials, for example silicon or copper in
certain cast aluminium scrap.
always contain small amounts of elements that do not have a particular function in the
recovered material. These elements may be metals or non-metals, which occasionally
occur in parts of the waste from which the recovered material originates. (The proposed
end-of-waste criteria limit the possible total content of foreign components to about 5 %
by weight and exclude any aluminium scrap that has hazardous properties included in
Annex III of the Waste Framework Directive.)

From these considerations, it follows that aluminium scrap with end-of-waste status can often
be considered a mixture under REACH which contains several metals. The components
mentioned under a) and b) above, for example, can be considered substances under REACH.
More specifically, they can be considered recovered substances. The elements mentioned under
c) can be considered impurities that need not be registered. Irrespective of whether those
impurities are original impurities of the substance or whether they are steriles in the metal scrap,
they will need to be allocated as impurities of the substance(s) in the mixture. This is needed if

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Impacts

there are impurities that are relevant in terms of the naming of the substances and the sameness
question for the purposes of the application of Article 2(7)(d).(6)
Registration of substances in aluminium scrap with end-of-waste status
Following the argumentation above, the substances contained in aluminium scrap with end-ofwaste status are recovered substances (metals). REACH registration of recovered metals is not
required when they comply with the conditions of Article 2 (7)(d) of REACH:

the metals have been registered (Article 2(7)(d)i; and

the relevant safety information is available (Article 2(7)(d)ii).

As the following assessment will show, it can be expected that these conditions can normally be
met without disproportionate efforts. This implies that in practice, processors will not have to
register any substances under REACH. Industry associations can contribute decisively to keep
the burden low for companies that want to demonstrate compliance with these conditions.
Regarding Article 2(7)(d)i
Recovered substances in aluminium scrap
Under REACH, recovered aluminium scrap can be considered either a single recovered
substance (aluminium) or a mixture containing various recovered substances (aluminium and
other alloying metals).
Wrought aluminium scrap meeting the end-of-waste criteria could often be considered a
substance (aluminium). All other constituents would qualify as impurities, should the scrap not
have been selected for their presence.
Cast aluminium scrap will, in most cases, consist of alloyed metal and therefore contains further
metals with a function such as copper, silicon, iron or manganese. They would have to be
considered substances subject to registration under REACH.
Will a substance be registered or has it already been registered?
The meeting on 14 October in Brussels revealed that aluminium and the other main metals used
in aluminium alloys will be registered by the December 2010 deadline. Metals used only for
special and rarer alloys may be manufactured and imported in lower quantities so that
registration may happen according to later deadlines. In any case, industry representatives
expect that these metals also be registered by the time producers of aluminium scrap with endof-waste status are faced with the need to apply the Article 2(7)(d) exemption.
In summary, industry expects that all relevant substances in metal scrap will be registered when
this is needed for the application of the exemption under Article 2(7)(d).(7)
Sameness
The CA document 24/2008/rev3 explains that in assessing whether the recovered substance is
the same as a substance that has already been registered or whether the substances are different,
recovery installations need to apply the rules of the guidance on substance identification and the
guidance on data sharing.
The CA document notes that variations in the composition and the impurity profile, including a
variation in the percentage of impurities, do not necessarily mean that substances are different.
According to the guidance on data sharing, for substances with a well-defined composition (i.e.
mono-constituent and multi-constituents substances) the sameness of the naming is in principle
(6) Failing this, the scrap metal as a whole would be seen as one substance and hence could be subject to registration.
(7) This assumes that the end-of-waste criteria will not enter into force until December 2010.

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Impacts

sufficient to be able to share data even though certain impurities might lead to a different
classification/hazard profile. Only in cases where all data is clearly not suitable for the other
substance these substances can be regarded as different (e.g. in case of very different physical
properties which have essential impact on the hazard properties, like water solubility).
It should be noted that the possible amounts and variation of impurities are limited by the endof-waste criteria. Aluminium scrap that complies with the end-of-waste criteria will contain
only very limited amounts of substances other than aluminium and other metals. This will be
ensured by the end-of-waste criteria by limiting the content of foreign materials and by the
process requirements. Foreign materials that would change the hazardous properties of the
recovered metal scrap are excluded by the end-of-waste criteria. This facilitates considering the
metals contained in aluminium scrap to be the same substances as the substances produced by
the producers of aluminium and the other metals.
In this context it is useful to highlight again that impurities (whether from original impurities of
the substance or from foreign materials in the metal scrap) will need to be allocated as
impurities of the substance(s) registered and identified in the metal scrap as subject to
registration. This is needed in terms of the naming of the substance and the sameness for the
purposes of the application of Article 2(7)(d). Failing this, the scrap metal as a whole would be
seen as one substance, which could mean that identifying sameness with the registered
substance could be more difficult.
The responsibility for determining sameness lies in the hands of the producers of aluminium
scrap that apply the end-of-waste status as the manufacturers of the substances.(8) There is no
confirmation given on sameness by the European Chemicals Agency. The manufacturer will
need to have information on the substance itself and its impurities(9).
European recycling industry associations have announced that they will prepare standard
documents with the necessary information (including the chemical composition of the different
scrap categories) and guidance that will allow individual companies to decide about the
sameness of substances. The guidance may also explain how to allocate any impurities in
mixtures to the individual substances. It is therefore not expected that individual companies will
have to carry any testing or chemical analysis in order to demonstrate the sameness of the
substances.
Regarding Article 2(7)(d)ii
Article 2(7)(d)ii provides that the information required by Articles 31 or 32 relating to the
substance that has been registered in accordance with Title II is available to the establishment
undertaking the recovery. Such an establishment will normally not receive safety data sheets
(SDS) or other safety information in the framework of Title IV of REACH, so to benefit from
the registration exemption, the required information must be available by other means. The
manufacturer can use any available information, starting with the information on the ECHAs
website and published in accordance with Article 119, but must make sure that no property
rights are violated. When using an existing SDS, legitimate access to the information must be
ensured. The same applies to other safety information, if required.
Article 32 information will be sufficient for most of the other substances that may appear in
aluminium scrap. The information required under Article 32 (i.e. if no safety data sheet is
required) is rather limited (registration number, information on authorisation and restriction if

(8) As stated in the CA document 24/2008/rev.2 on Waste and recovered substances: [] all forms of recovery are
[] considered as a manufacturing process whenever, after having undergone one or several recovery steps, they
result in the generation of one or several substances that have ceased to be waste.
(9) If the manufacturer has pre-registered the substance, discussions within the SIEFs will allow companies to address
sameness and refine and if necessary correct substance identity, as long as it is clear that the pre-registration was done
for the concerned substance.

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Impacts

any, and any other available and relevant information to enable appropriate risk management
measures).
Industry associations have expressed that they will prepare standard information for their
members. Having access to such standard information will allow individual companies to show
that the required information under Article 2(7)(d) is available to the establishment undertaking
the recovery.
Imports
The exemptions under Article 2(7)(d) apply only to substances which are recovered in the
Community. It should be noted that Recital 22 of the WFD says that for the purposes of
reaching end-of-waste status, a recovery operation may be as simple as the checking of waste to
verify that it fulfils the end-of-waste criteria. If the waste is checked to verify that it fulfils the
end-of-waste criteria after it has been imported in the Community and not before, then it would
have waste status when it is imported and it seems logical then to consider that the substances it
contains are recovered in the Community.
Provision of information required under Articles 31 or 32 of REACH
According to Articles 31 and 32 of the REACH Regulation, suppliers of substances or mixtures
have to provide the recipients with safety information. This requirement is not exempted under
Article 2(7)(d) for recovered substances. For certain substances and mixtures, safety
information is required in the form of safety data sheets (SDS) according to Article 31. If SDS
are not needed, safety information according to Article 32 must be provided. Normally an SDS
will not be needed for end-of-waste scrap unless the scrap has to be classified as dangerous
because of the content of certain alloys, because the end-of-waste criteria do not allow the scrap
to have hazardous properties for other reasons. The assessment below discusses this in more
detail.
When is it necessary to provide an SDS (Article 31)?
1.

An SDS, including where relevant (>10 t/yr) exposure scenarios, must be provided when:
a.

b.
c.
d.

2.

The substance/mixture meets criteria for classification as dangerous in accordance

with Council Directive 67/548/EEC (Dangerous Substances Directive) or Directive
1999/45/EC of the European Parliament and of the Council (Dangerous
Preparations Directive) (Article 31(1)(a) of REACH); or
The substance on its own or in a mixture is a persistent, bioaccumulative and toxic
chemicals (PBT), very persistent, very bioaccumulative (vPvB) in accordance with
criteria set out in Annex XIII (Article 31(1)(b) of REACH); or
The substance on its own or in a mixture is on the REACH Candidate list (Art
31(1)(c) of REACH); or
The customer has requested an SDS (Article 31(4) of REACH). For commercial
reasons, a recycler may choose to produce an SDS at the request of a customer,
even if not legally obliged to do so. Article 31(4) specifies that an SDS need not be
supplied where dangerous substances or mixtures offered or sold to the general
public are provided with sufficient information (Article 31(4) ie. SDSs are only for
professional users (downstream user or distributor under REACH).

The supplier shall provide the recipient at his request with a SDS where mixtures do
not meet the criteria for classification as dangerous but contains an individual
concentration of 0.1 % by weight for non-gaseous mixtures at least one substance that is
PBT or vPvB in accordance with the criteria set out in Annex XIII or has been included in
the list established in accordance with Article 59(1) or a substance for which there are
Community workplace exposure limits (Article 31(3)).

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Obligations under Article 32

In the case where a supplier is not required to provide an SDS, the supplier still needs to comply
with Article 32 of REACH: the duty to communicate information down the supply chain for
substances on their own or in mixture for which an SDS is not required. The information to be
provided includes:
a.
b.
c.
d.

registration number(s), if available;

if the substance is subject to authorisation;
details on any restriction imposed;
any other available and relevant information about the substance that is necessary to
enable appropriate risk management measures to be identified and applied.

Such information should be provided free of charge and at the time of delivery (Article 32(2)).
The information should be updated in cases where new information on hazards or risk
management measures are available or in cases where the substance is subject to authorisation
or restriction (Article 32(3)).
Information requirements for aluminium scrap with end-of-waste status
The cases where an SDS is needed will be very limited because the end-of-waste criteria for
aluminium scrap will exclude a scrap which ceases to be waste that has any of the properties
which render waste hazardous (Annex III WFD), with the exception mentioned in the next
paragraph. For most of the properties, the same criteria have to be applied as according to the
Dangerous Substances Directive and the Dangerous Preparations Directive. It should also be
noted that in the meeting on 14 October 2009, industry associations representing the users of
aluminium scrap expressed that the users have no interest in demanding SDSs from the
aluminium scrap suppliers because they would regard this as unnecessary paperwork.
The end-of-waste criteria will, however, allow metals contained in metal scrap even if they are
dangerous substances, and an SDS may be required in such a case.
A producer of aluminium scrap that applies the end-of-waste status does not have to generate a
chemical safety report or exposure scenario for a substance (or substance in a mixture) that is
exempted from registration (under Article 2(7)(d). The same safety information that must be
available to fulfil the condition under Article 2(7)(d)(ii) can usually be used for communicating
the information down the supply chain.
The information required under Article 32, i.e. if no SDS is required, will be limited to any
other available and relevant information to enable appropriate risk management measures. For
recovered substances that have not been registered (Article 2(7)(d) exemption), no registration
numbers or information on authorisation or restriction have to be supplied.
Compilation of information to comply with safety information requirements
Producers of aluminium scrap with end-of-waste status are generally not downstream users
under REACH and will therefore not automatically receive safety information together with the
waste materials intending to be processed. The information chain stops at the last downstream
user and, consequently, post-consumer waste does not come with safety information.
European industry associations have, however, committed themselves to preparing guidance
and standard documents for the provision of information in the supply chain and an SDS for
recovered substances and mixtures in accordance with Articles 2(7)(d), 31 and 32 of REACH.
The use of such standard information would allow for minimising the burden individual
companies may face.
Such standard documents should cover all relevant (downstream) uses of the scrap. The
standard documents should consider fully any guidance developed by ECHA on this issue in
order to ensure the acceptance by the competent authorities of information provided by
individual suppliers according to the standard documents.
48

Impacts

The same safety information that must be available to fulfil the condition under Article
2(7)(d)(ii) can be used for communicating the information down the supply chain. (It is
understood that this applies also to the exposure scenarios, if these are required for a substance.)
Reverse VAT (Value Added Tax)
Concerns were raised in the technical working group that the end-of-waste status of scrap may
in certain countries affect the applicability of reverse VAT charges on scrap. It should be noted
that the end-of-waste criteria are not intended to change the way in which VAT is payable on
scrap. It would therefore be preferable that scrap-specific provisions in national VAT law refer
directly to scrap as a good, regardless of the status as waste or not (end-of-waste).

49

Conclusions

CONCLUSIONS

Thanks to the strong support from the TWG, it has been possible to develop proposals for endof-waste criteria for aluminium scrap that:

are in compliance with all the conditions given by Article 6 of the Waste Framework
Directive;
would be operational in practice; and
would deliver clear benefits.

The main concerns that were raised, to different degrees by different experts and stakeholders,
were about the implications and possible burdens under REACH. An in-depth assessment of the
impacts related to REACH was carried out and has shown that REACH allows solutions so that
disproportionate burdens for the industries can be avoided.

It can be expected that recycling markets will benefit strongly from harmonised, EU-wide
end-of-waste criteria for aluminium scrap.

There is a clear need for Community-wide end-of-waste criteria for aluminium scrap.
Aluminium scrap represents one of the major material recycling flows and is traded across the
EU and worldwide. Under the old Waste Framework Directive and the corresponding case law
aluminium scrap was considered waste until it was melted in a furnace for the production of
new metal. The new Waste Framework Directive introduced the concept of end-of-waste status
and the possibility to develop end-of-waste criteria at the community level. Where end-of-waste
have not been set at the Community level, Member States may decide case by case whether
certain waste has ceased to be waste, taking into account the applicable case law. However,
many experts and stakeholders believe that case-by-case decisions are not desirable for
materials that are traded internationally in substantial amounts and that Community-wide endof-waste criteria are needed in such cases for the good functioning of the internal market and
also for the protection of the environment and human health.

'Early end-of-waste allows for reducing administrative burden and compliance costs.

Most of the experts in the TWG have supported the early end-of-waste approach, i.e. that
aluminium scrap may cease to be waste when it has been mechanically processed and has
obtained a sufficient quality that regulatory controls under waste regulation are no longer
needed to protect the environment and human health. A direct advantage, compared to late endof-waste as under the old Waste Framework Directive, is that the administrative burden and
paperwork under the waste regulation will be eliminated for compliant material. Such an
advantage weighs especially high when scrap demand in Europe is relatively weak and prices
are lower, such as in times of economic crisis.

The end-of-waste criteria allow for consolidating the status of compliant aluminium scrap
as high-quality secondary raw-material.

The proposed end-of-waste criteria imply reinforcing the quality assurance for aluminium scrap.
This will further improve its reliability as high quality raw-material and strengthen consumer
confidence in the product.

Disproportionate burden under REACH is avoidable, but support by the different industry
associations, guidance by the relevant European bodies and as much legal certainty as
possible are needed.

The main concerns regarding early end-of-waste for aluminium scrap are related to REACH
and the fact that the general exemption of waste from most obligations under the REACH
Regulation will not apply to scrap with end-of-waste status. The REACH impact assessment has
51

Conclusions

shown that it is possible for individual companies to avoid excessive burden under REACH.
However, uncertainties remain, notably about the guidance that will be provided by industry
associations and its acceptance by the authorities. Furthermore, under current law, registration
would be required for scrap that is imported to the Community under end-of-waste status. How
widely the end-of-waste criteria for aluminium scrap will be accepted, will to a large extent
depend on the degree of legal certainty that can be established about the obligations and nonobligations under REACH.
Guidance by the relevant European bodies could make an important contribution in this sense. It
is also notable that during the intensive discussion of the REACH implications of end-of-waste
for aluminium scrap, no opinions were expressed that registration of the substances in the scrap
was required to fulfil the objectives of REACH. Instead, the discussions were characterised by
attempts to find a solution to the REACH problem. There seems therefore to be a case for
considering a legal exemption of end-of-waste scrap from registration obligations. Such an
assessment is, however, clearly not within the scope of this report.

52

References

REFERENCES

BIR, Report on the environmental benefits of recycling, 2008

Commission document CA/24/2008 rev.3, which was produced as a follow up to the 5th
Meeting of the Competent Authorities for the implementation of Regulation (EC) 1907/2006
(REACH)
Council Regulations 1420/1999 establishing common rules and procedures to apply to
shipments to certain non-OECD countries of certain types of waste
Commission Regulation 1547/1999 determining the control procedures under Council
Regulation (EEC) No 259/93 to apply to shipments of certain types of waste to certain countries
to which OECD Decision C(92)39 final does not apply
Directive on Batteries and Accumulators, Directive 2006/66/EC of the European Parliament and
of the Council of 6 September 2006 on batteries and accumulators and waste batteries and
accumulators and repealing Directive 91/157/EEC
Directive 94/62/EC on packaging and packaging waste
Directive 96/29/Euratom laying down basic safety standards for the protection of the health of
workers and the general public against the dangers arising from ionizing radiation.
End of waste criteria, report JRC-IPTS, 2008
EC Directive 2006/117/Euratom on the supervision and control of shipments of radioactive
waste and spent fuel
ELV Directive; Directive 2000/53/EC of the European Parliament and of the Council on end-of
life vehicles, 2000
EN 13920-1:2002; Aluminium and aluminium alloys - Scrap- Part 1: General requirements,
sampling and tests; CEN 2002
European Waste List, European Waste Catalogue, Commission Decision, 2002
ISRI specification, Scrap Specification Circular, Institute of Scrap Recycling Industries, Inc.,
2008
REACH Regulation, Regulation (EC) No 1907/2006 of the European Parliament and of the
Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals
(REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and
repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94
as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC,
93/105/EC and 2000/21/EC
UNECE Recommendations on Monitoring and Response Procedures for Radioactive Scrap
Metal; Report of an International Group of Experts convened by the United Nations Economic
Commission for Europe (UNECE); United Nations Economic Commission for Europe; New
York and Geneva, 2006.
Waste Framework Directive (WFD), Directive 2008/98/EC on waste

53

References

Waste Shipment Regulation, Regulation (EC) No 1013/2006 of the European Parliament and of
the Council on shipments of waste
WEEE Directive, Directive 2002/96/EC of the European Parliament and of the Council of 27
January 2003 on waste electrical and electronic equipment (WEEE)

54

Annexes

ANNEXES

55

Annex 1

Annex 1. Summarised standards en 13920 on aluminium and

aluminium alloy scrap.
a

13920-2 (Unalloyed aluminium scrap)

Metal yield is typically 95 %. Composition (mass fraction) Simax=0.25 %; Femax= 0.4 %,
Cumax=0.05 %; Mnmax=0.05 %, Mgmax=0.05 %; Znmax=0.07 %, Timax=0.05 %, others each
max.0.05 %.

13920-3 (Wire and cable scrap)

Metal yield shall be 95 %. Composition (mass fraction) of unalloyed aluminium
Simax=0.25 %; Femax= 0.4 %, Cumax=0.05 %; Mnmax=0.05 %, Mgmax=0.05 %; Znmax=0.07 %,
Timax=0.05 %, others each max.0.03 %. Composition (mass fraction) of alloys of the 6xxx
series Simax=0.6 %; Femax= 0.3 %, Cumax=0.05 %; Mnmax=0.05 %, Mgmax=0.06 %;
Crmax=0.05 %; Znmax=0.07 %, Timax=0.10 %, others each max.0.05 %, others total max.
0.15 %.

13920-4 (Scrap consisting of one single wrought alloy)

Metal yield shall be 95 %. Composition of a wrought alloy as specified in EN 573-3 or
another registered alloy.

13920-5 (Scrap consisting of two or more wrought alloys of the same series)
Metal yield shall be 88 %. Composition (mass fraction) differs for different basis (multipurpose base, basis for 2xxx series, basis for 3xxx series, basis for 5xxx series, basis for
6xxx series and basis for 7xxx series).

13920-6 (Scrap consisting of two or more wrought alloys)

Metal yield shall be 88 %. Composition (mass fraction) differs for chemical composition
of grade A and grade B.

13920-7 (Scrap consisting of castings)

Metal yield shall be 90 %. Composition (mass fraction) Simax=13.5 %; Femax= 1.1 %,
Cumax=3.5 %; Mnmax=0.5 %, Mgmax=0.3 %; Nimax=0.3 %; Znmax=1.2 %, Timax=0.15 %;
Pbmax=0.2 %; Snmax=0.1 %, others each max.0.15 %.

13920-8 (Scrap consisting of non-ferrous materials from shredding processes destined to

aluminium separation processes)
Metal yield shall be 90 %. Composition (mass fraction) Simax=9.0 %; Femax= 1.1 %,
Cumax=3.5 %; Mnmax=0.5 %, Mgmax=0.5 %; Nimax=0.3 %; Znmax=1.2 %, Timax=0.15 %;
Pbmax=0.2 %; Snmax=0.1 %, others each max.0.15 %.

13920-9 (Scrap from aluminium separation processes of non-ferrous shredded materials)

Metal yield shall be 90 %. Composition (mass fraction) Simax=9.0 %; Femax= 1.1 %,
Cumax=3.5 %; Mnmax=0.5 %, Mgmax=0.5 %; Nimax=0.3 %; Znmax=1.2 %, Timax=0.15 %;
Pbmax=0.2 %; Snmax=0.1 %, others each max.0.15 %.

13920-10 (Scrap consisting of used aluminium beverage cans)

Metal yield shall be 88 %. Composition (mass fraction) Simax=0.3 %; Femax= 0.5 %,
Cumax=0.2 %; Mnmax=1.1 %, Mgmax=1.3 %; Nimax=0.01 %; Znmax=0.05 %, Timax=0.05 %;
Pbmax=0.01 %; Snmax=0.05 %, others each max.0.05 %, others total max. 0.15 %.

13920-11 (Scrap consisting of aluminium-copper radiators)

Metal yield not proposed. Composition (mass fraction) Femax= 0.7 %, Cumax=40 %; other
impurities max. 0.2 %; Almin =remainder.

13920-12 (Turnings consisting of one single alloy)

56

Annex 1

Metal yield shall be 90 %. The scrap shall be unoxidised and the following tolerances
apply to the delivered mass: 0.5 %(mass fraction) of magnetic iron; 5 % (mass fraction) of
moisture and oil; 3 %(mass fraction) of fines passing through a 20 mesh sieve, after drying.
l

13920-13 (Mixed turnings consisting of two or more alloys)

Metal yield shall be 90 %. The scrap shall be unoxidised and the following tolerances
apply to the delivered mass: 0.5 %(mass fraction) of magnetic iron; 5 % (mass fraction) of
moisture and oil; 3 %(mass fraction) of fines passing through a 20 mesh sieve, after drying.

m 13920-15 (De-coated aluminium scrap from post-consumer aluminium packaging)

Metal yield shall be 80 %. Composition (mass fraction) Simax=1.0 %; Femax= 1.0 %,
Cumax=2.5 %; Mnmax=0.4 %, Mgmax=0.2 %; Znmax=0.8 %, Pbmax+Snmax=0.2 %, other each
max.0.1 %.
n

13920-14 (Scrap from post-consumer aluminium packaging)(10)

Metal yield shall be 28 %. Composition (mass fraction) Simax=1.0 %; Femax= 1.0 %,
Cumax=2.5 %; Mnmax=0.4 %, Mgmax=0.2 %; Znmax=0.8 %, Pbmax+Snmax=0.2 %, other each
max.0.1 %.

13920-16 (Scrap consisting of skimmings, drosses, spills and metallics)10

Metal yield shall be 30 %. The scrap shall be free from moisture and other foreign
material such as refractories, stones, plastics and wood.

(10) This scrap category should not be accepted for end-of-waste due to the low metal yield.
57

Annex 2

Annex 2. Aluminium scrap categories according to Institute of Scrap

Recycling Industries (ISRI).
Tablet CLEAN ALUMINUM LITHOGRAPHIC SHEETS
Tabloid NEW, CLEAN ALUMINUM LITHOGRAPHIC SHEETS
Taboo MIXED LOW COPPER ALUMINUM CLIPPINGS AND SOLIDS
Taint/ CLEAN MIXED OLD ALLOY SHEET ALUMINUM
Take NEW ALUMINUM CAN STOCK
Talc POST-CONSUMER ALUMINUM CAN SCRAP
Talcred SHREDDED ALUMINUM USED BEVERAGE CAN (UBC) SCRAP
Taldack DENSIFIED ALUMINUM USED BEVERAGE CAN (UBC) SCRAP
Taldon BALED ALUMINUM USED BEVERAGE CAN (UBC) SCRAP
Taldork BRIQUETUED ALUMINUM USED BEVERAGE CAN (UBC) SCRAP
Tale PAINTED SIDING
Talk ALUMINUM COPPER RADIATORS
Tall E.C. ALUMINUM NODULES
Tally ALL ALUMINUM RADIATORS FROM AUTOMOBILES
Talon NEW PURE ALUMINUM WIRE AND CABLE
Tann NEW MIXED ALUMINUM WIRE AND CABLE
Tarry A CLEAN ALUMINUM PISTONS
Tarry B CLEAN ALUMINUM PISTONS WITH STRUTS
Tarry C IRONY ALUMINUM PISTONS
Tassel OLD MIXED ALUMINUM WIRE AND CABLE
Taste OLD PURE ALUMINUM WIRE AND CABLE
Tata NEW PRODUCTION ALUMINUM EXTRUSIONS
Toto ALUMINUM EXTRUSIONS 10/10
Tutu ALUMINUM EXTRUSION DEALER GRADE
Teens SEGREGATED ALUMINUM BORINGS AND TURNINGS
Telic MIXED ALUMINUM BORINGS AND TURNINGS
Tense MIXED ALUMINUM CASTINGS
Tepid AIRCRAFT SHEET ALUMINUM
Terse NEW ALUMINUM FOIL
Tesla POST CONSUMER ALUMINUM FOIL
Tetra NEW COATED ALUMINUM FOIL
Thigh ALUMINUM GRINDINGS
Thirl ALUMINUM DROSSES, SPATTERS, SPILLINGS, SKIMMINGS AND SWEEPINGS
Throb SWEATED ALUMINUM
Tooth SEGREGATED NEW ALUMINUM ALLOY CLIPPINGS AND SOLIDS
Tough MIXED NEW ALUMINUM ALLOY CLIPPINGS AND SOLIDS
Tread SEGREGATED NEW ALUMINUM CASTINGS, FORGINGS AND EXTRUSIONS
Troma Aluminum Auto or Truck Wheels
Trump ALUMINUM AUTO CASTINGS
Twang INSULATED ALUMINUM WIRE SCRAP
Twist ALUMINUM AIRPLANE CASTINGS
Twitch FLOATED FRAGMENTIZER ALUMINUM SCRAP (from Automobile Shredders)
Tweak FRAGMENTIZER ALUMINUM SCRAP (from Automobile Shredders)
Twire BURNT FRAGMENTIZER ALUMINUM SCRAP (from Automobile Shredders)
Saves OLD ZINC DIE CAST SCRAP
Scabs NEW ZINC DIE CAST SCRAP
Scoot ZINC DIE CAST AUTOMOTIVE GRILLES
Scope NEW PLATED ZINC DIE CAST SCRAP
Score OLD SCRAP ZINC

58

Annex 3

Annex 3. Summarised criteria

Criteria
Product quality
Foreign materials
The total amount of foreign materials shall be
5 % by weight or the metal yield shall be
90 %
The scrap shall not contain excessive metal
oxide in any form, except for typical amounts
arising from the outside storage of prepared
scrap under normal atmospheric conditions

Remarks

Self monitoring

Explanation

Foreign materials are

Foreign materials should be determined by:

1. Visual inspection for every load by

qualified staff and
2. At appropriate intervals, sampling shall
be carried out according to standard EN
13920-1. Foreign materials shall be
determined by manual sorting of
aluminium metallic particles or objects
from non-metallic or other metallic
particles or objects based on careful
visual inspection or other means of
detecting metal (analysis by magnet,
based on the density of materials, etc.)

Frequency of monitoring includes both the

number of times a parameter is monitored
over any given time period and the duration
of each monitoring event so that it is a
representative sample of the total. In the
absence of historical results for any relevant
parameter, it is considered good monitoring
practice to carry out an intensive monitoring
campaign over a short period (e.g. a month
or a few months) in order to characterise the
material stream and provide a basis for
determining an appropriate, longer-term
monitoring frequency. The process of
determining monitoring frequencies should
be documented as part of the overall quality
assurance scheme and as such should be
available for auditing. The result of the
monitoring frequency determination should
provide a stated statistical confidence (often
a 95 % confidence level is used) in the
ultimate set of monitoring results

metals other than

aluminium
and
aluminium alloys
non-metallic
materials such as
earth, dust, insulation
and glass
combustible
nonmetallic
materials
such
as
rubber,
plastic, fabric, wood
and other chemical
or organic substances
larger pieces (bricksized) which are nonconductors
of
electricity such as
tyres, pipes filled
with cement, wood
or concrete

The determination of foreign materials

could be optionally (e. g. for very fine
particles) replaced by melting analysis,
determining metal yield. Sampling and
testing to determine the metal yield shall be
carried out according to standard EN 13920
The appropriate frequencies of monitoring
shall be established by consideration of the
following factors:

the expected pattern of variability

(for example as shown by historical
results);
the inherent risk of variability in raw
material input quality and any
subsequent processing;
the inherent precision of the
monitoring method; and
the proximity of actual results to the
limit of compliance with the relevant

The Commission adopted a reference

document in July 2003 entitled Reference
Document on Best Available Techniques for
General Principles of Monitoring which was
developed under the provisions of the IPPC
Directive but which remains a relevant
reference document for the determination of
appropriate monitoring frequencies in this
respect. It is available for download from the
web
site
at:
http://eippcb.jrc.es/reference/_download.cfm
?twg=mon&file=mon_bref_0703.pdf.

59

Annex 3
Criteria

Remarks

Self monitoring

end-of-waste condition
The process of determining monitoring
frequencies should be documented as part
of the overall quality assurance scheme and
as such should be available for auditing
The scrap should be investigated by visual
inspection for the presence of oxides; a
typical amount arising from outside storage
of prepared scrap under normal atmospheric
conditions is acceptable

Explanation
Analysing procedure to determine metal
yield (e.g. for fine granulated aluminium
scrap and turnings):
1.
2.
3.
4.

removal and determination of

moisture (according to 7.1. of the EN
13920-1:2002)
removal and determination of free
iron (according to 7.2. of the EN
13920-1:2002)
determination of the metal yield
(according to 7.3. of the EN 139201:2002)
the metal yield will be calculated as a
mass after melt (m4) and the mass
after determining the moisture content
(m2); m [%] =(m4/m2) 100
Mass (m1)
(aluminium scrap sample input)

Mass (m2)
(after drying at 105 C and 360 C)

Mass (m3)
(after removal of free iron)

Mass (m4)
(after melting)
Oil, oily emulsion, lubricants or grease
Scrap shall be free of visible oil, oily emulsion,
lubricants or grease

60

Visual inspection of each consignment by

qualified staff

Oil, oily emulsion, lubricants or grease

should not be visible in any part of the scrap
load, except negligible amounts that will not
lead to any dripping. Visual inspection shall
pay particular attention to those parts of the

Annex 3
Criteria

Remarks

Self monitoring

Hazardous materials
The scrap does not have any of the properties
included in Annex III of the Directive
2008/98/EC of the European Parliament and of
the Council on waste (properties of waste
which render it hazardous)

Properties of individual
metal elements included in
aluminium
alloys
are,
however, not relevant for
this requirement.

Visual inspection of each consignment by

qualified staff

Explanation
load where oil is most likely (the bottom).
Staff shall be trained on potential hazardous
properties that may be associated with
aluminium scrap and on material
components or features that allow for
recognising the hazardous properties.
The procedure of recognising hazardous
materials shall be documented under the
quality assurance system

The scrap does not contain any pressurised,

closed or insufficiently open containers of any
kind that could cause explosions in a metalwork
furnace
Radioactivity
The following must be excluded: material
presenting radioactivity in excess of the
ambient level of radioactivity; and radioactive
material in sealed containers even if no
significant exterior radioactivity is detectable
due to shielding or due to the position of the
sealed source in the scrap delivery

Visual inspection of each consignment by

qualified staff
It must be ensured that each consignment is
monitored for radioactivity
Each consignment/shipment of scrap shall
be accompanied by a completed certificate
according to Annex I of the 2006 UNECE
Recommendations on Monitoring and
Response Procedures for Radioactive Scrap
Metal or an equivalent certificate according
to national rules). (The certificate may be
included
in
other
documentation
accompanying the consignment/shipment.)

All scrap grades shall be checked as early as

possible, preferably at the origin of the
material source when scrap enters the
material chain, and in all subsequent stages
of the scrap supply chain, in strict
compliance with state-of-the-art and the
most efficient detection equipment and
within the limitations of accessibility to
identify radioactive materials

This certificate shall have been issued by

the operator of the detection equipment

Grading
The scrap shall be graded according to a
customer specification, a standard or an
industry specification for direct input to one of

Certificates may be provided in electronic

form. For multiple shipments to the same
customer, and with the agreement of the
customer, a single certificate may be
supplied to demonstrate that all loads have
been monitored
Each consignment shall be graded by
qualified staff

The specification used may be of an agreed

upon nature across an industry sector (e.g.
EN 13920:2002, ISRI) or may be defined by
one or more individual final use companies
61

Annex 3
Criteria
the final uses (e.g. production of metal
substance or objects by refining/remelting)
Coatings, paints, plastics
The scrap shall not contain PVC
Input materials
No other waste shall have been used as input to
obtain the scrap than waste that contained
recoverable aluminium at source

Remarks

Self monitoring
Visual inspection of each consignment by
qualified staff
Acceptance control of all input material
received (visual inspection) and of the
accompanying documentation by qualified
staff

No hazardous waste shall have been used as

input to obtain the scrap except:

wastes that are covered by the WEEE

Directive or the ELV Directive

discarded
equipment
containing
chlorofluorocarbons (CFC) that do not
have any hazardous properties except
those due to the chlorofluorocarbon
content

other hazardous waste for which proof is

provided that suitable treatment to
remove all hazardous properties is
applied in a treatment process which is
approved by authorities
Processes and techniques
The aluminium scrap shall have been
segregated at the source or while collecting and
shall have been kept separate; or the input
wastes shall have been treated to separate the
aluminium scrap from the non-metal and nonferrous components.
All mechanical treatment (like cutting,
shearing, shredding or granulating; sorting,
separation, cleaning, de-polluting, emptying)
needed to prepare the material for direct input
into final use shall have been completed
Specific requirements:
62

Explanation

The requirements on input materials shall

be included in the specifications/contract
with the suppliers

All required treatments shall have been

completed. Compliance to be assessed by
the undertaking applying the end-of-waste
criteria based on knowledge on the
treatment applied to the input materials and
on the own treatments

Acceptance control procedures shall be

covered by the quality assurance system
This would normally include that the
undertaking applying the end-of-waste
criteria requires certain quality assurance
also by the supplier.
Staff carrying out the acceptance control
shall be trained on how to recognise
operationally input material that does not
fulfil the requirements

Annex 3
Criteria

input materials that originate from endof-life vehicles or waste electronic or

electric equipment shall have completed
all treatments as required by the ELV
Directive (Article 6) and the WEEE
Directive (Article 6).

discarded
equipment
containing
chlorofluorocarbons, (CFCs) must have
been captured in an approved process

filings and turnings that contain cutting

fluids such as oils must have been
treated to remove these fluids by
processes like centrifugation or pressing

cables must have been stripped or

granulated. If a cable contains organic
coatings (plastics), the organic coatings
must have been removed according to
the best available techniques

barrels and containers including inter

alia oil and paint drums, shall have been
emptied and cleaned

hazardous substances shall have been

efficiently removed
Quality assurance
The acceptance of input materials, all treatment
steps and product quality checks (including any
sampling and testing or visual inspections)
according to the end-of-waste criteria must
have been carried out under a fully
implemented and externally verified quality
management system

Remarks

Self monitoring

Explanation

The quality management system must at least

include the following elements:
1.

the quality management system must be

auditable and ready for inspection by the
competent authority under waste law to
satisfy itself that the system is suitable
63

Annex 3

2.

Criteria
for the purpose of demonstrating
compliance with end-of-waste criteria
must include a set of documented
procedures addressing each key
process relevant to compliance with
the technical end-of-waste criteria,
including:

64

acceptance of input materials

monitoring of processes to
ensure they are effective at all
times
monitoring product quality
(including
sampling
and
analysis) that are adjusted to
the process and product
specifics according to good
practice;
procedures that ensure the
effectiveness of the radiation
monitoring and the ability of
the radiation monitors to
detect changes in radiation
intensity
actively soliciting feedback
from customers in order to
confirm compliance with
product documentation
record keeping of main quality
control parameters
measures for review and
improvement of the quality
management system
training of staff.

Remarks

Self monitoring

Explanation

Annex 3
Criteria
Information provided with the product
Each consignment of the aluminium scrap or
multiple loads to the same customer shall either
be accompanied by the following information
or be available in electronic form to the
customer and upon the request of any
competent authority:

Remarks

Self monitoring

Explanation
All information could be described in one or
several documents

the name or code of the scrap

category according to a specific
product standard or specification and
a declaration of compliance with the
standard or specification;
a radioactivity test certificate in
accordance with the UNECE
Recommendations on Monitoring
and Response Procedures for
Radioactive Scrap Metal or similar
certificate according to national
rules);
identification of the external verifier
or the certification of the quality
assurance system;
statement of conformity to the endof-waste criteria;
whether or not the scrap complies
with the limit for foreign materials
or metal yield.

65

European Commission
EUR 24396 EN Joint Research Centre Institute for Prospective Technological Studies
Title: End-of-waste Criteria for Aluminium and Aluminium Alloy Scrap: Technical Proposals
Authors: Lenka Muchov and Peter Eder
Luxembourg: Publications Office of the European Union
2010
EUR Scientific and Technical Research series ISSN 1018-5593
ISBN 978-92-79-15990-9
doi:10.2791/43228
Abstract
This report is the JRC-IPTS contribution to the development of the end-of-waste criteria for aluminium scrap in
accordance with Article 6 of Directive 2008/98/EC of the European Parliament and of the Council on waste (the
Waste Framework Directive).
This report includes a possible set of end-of-waste criteria and shows how the proposals were developed based
on a comprehensive techno-economic analysis of aluminium and aluminium alloy recycling and an analysis of
the economic, environmental and legal impacts when aluminium scrap cease to be wastes. The purpose of endof-waste criteria is to avoid confusion about the waste definition and to clarify when certain waste that has
undergone recovery ceases to be waste. Recycling should be supported by creating legal certainty and an
equal level playing field and by removing unnecessary administrative burdens. The end-of-waste criteria should
provide a high level of environmental protection and an environmental and economic benefit.

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