What are recyclates?
As someone who has used the word “recyclate” many times over the years in the context of both planning and environmental permits, I have often just assumed that there is a common understanding of what it actually means — just as others appear to have done the same in many other permit applications and planning applications I have seen. However, in relation to some recent work that I have been doing, I thought that it would be good to quote an ‘official’ definition. So, what are recyclates?
Well here’s the definition from the Collins Dictionary -
Recyclate: noun. material that is recyclable.
Fair enough! Not really what I was looking for. A more legal slant would be better and so perhaps the following -
““Recyclate” means any waste segregated from household waste or trade waste receptacles and sent for treatment other than disposal by land filling or incineration” — Taken from numerous London Borough Waste Receptacle Regulations made under the relevant sections of the London Local Authorities Act.
OK, specific to London Boroughs so it would be nice to have something more general that could be applied throughout the country (although importantly here it does NOT include any waste sent for incineration which we’ll touch on again shortly).
The Revised Waste Framework Directive (rWFD)does not specifically define the term “recyclate” although does refer to it, providing a specific example of a recyclate within i.e. –
“Member States should support the use of recyclates, such as recovered paper, in line with the waste hierarchy and with the aim of a recycling society, and should not support the landfilling or incineration of such recyclates whenever possible**.”
It therefore refers to the aim of “recycling” which is a term defined within the rWD as well as the term “waste” to which it refers.
As such, taking in to account both of these terms (recycling and waste) and combining their respective definitions from within the rWFD in to a single definition, recyclates could be considered to be –
Recyclates are waste materials which are reprocessed into products, materials or substances whether for the original or other purposes by means of any recovery operation* including the reprocessing of organic material but not including energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations.
*Annex II of the rWFD includes a list of 13 recovery operations (R1-R13) although taking in to account the above, waste material for R1 (energy recovery including incineration if meets strict energy efficiency criteria) would not be deemed as a recyclate. Again, as before, any waste destined for incineration (even if deemed recovery via the R1 energy efficiency formula) could not qualify as a recyclate so RDF and MSW destined for an EfW would not be deemed recyclate in this case (even if containing recyclates such as metals that could be recovered from the post processing residues). So…
The recyclate definition that I have assembled from combining the two definitions (waste and recycling) from the rWFD would appear to be the best fit and in line with what I have always assumed to be the understanding. I am, however, interested to know if anyone else believes there is a better, more legally accurate definition available? Thoughts?
Follow up thought!
“…..and should not support the landfilling or incineration of such recyclates whenever possible**”
The odd thing about this statement is that if interpreted at face value then it is only advising against sending recyclates to landfill or incineration. So in this sense it is acknowledging that recyclates could actually go to landfill or incineration and so in that sense, being sent to landfill or incineration does not rule them out from actually being reyclates! In which case that is counter to everything I’ve said above. In which case (and in light of such ambiguity) — the requirement for an official legal definition is even more important.
