Questions & Answers
Can we assume that recycled waste can be calculated by subtracting non-recycled waste from total waste?
- Recycled waste
Background
ESRS E5-5 paragraph 37 states: ‘The undertaking shall disclose the following information on its total amount of waste from its own operations, in tonnes or kilogrammes:
(a) the total amount of waste generated;
(b) the total amount by weight diverted from disposal, with a breakdown between hazardous waste and non-hazardous waste and a breakdown by the following recovery operation types:
(i) preparation for reuse;
(ii) recycling; and
(iii) other recovery operations …
(d) the total amount and percentage of non-recycled waste.’
Directive 2008/98/EC (Waste Framework Directive (WFD)), Article 4, includes recycling as part of a waste hierarchy for waste management: ‘The following waste hierarchy shall apply as a priority order in waste prevention and management legislation and policy: (a) prevention; (b) preparing for re-use; (c) recycling; (d) other recovery, e.g. energy recovery; and (e) disposal’.
Answer
Yes, undertakings can assume that recycled waste can be calculated by subtracting non-recycled waste from total waste provided that they consider all proper components in the equation of the total waste (in order to understand what can be considered as ‘non-recycled waste’) and provided that they know all components except the one of recycled waste.
As per the Waste Framework Directive (WFD), these are the components that need to be considered in the equation of the total waste generated:
Total waste = recycled waste + reused waste + other recovery + disposed waste.
The above categories are to be understood as per definitions in the WFD:
(a) Recycled waste: any recovery operation by which waste materials are reprocessed into products, materials or substances. This includes the reprocessing of organic material but excludes energy recovery and reprocessing into materials used as fuels.
(b) Reused waste: involves checking, cleaning or repairing recovery operations by which products or components of products that have become waste are prepared to be re-used without other pre-processing.
(c) Other recovery: any waste-recovery operation that serves a useful purpose by replacing other materials. Notably, it includes energy recovery (e.g. incineration with energy recovery).
(d) Disposed waste: waste that is not recovered (recycled or otherwise diverted from disposal) and is sent to landfill or other disposal methods.
Nevertheless, given the equation, a missing component can be derived if the other components in the equation are known. To calculate recycled waste, if this component is not known and all others are, undertakings would have to use the following equation:
Recycled waste = total waste – (reused waste + other recovery + disposed waste)
Relations
Paragraph | Content |
|---|---|
The undertaking shall disclose the following information on its total amount of waste from its own operations, in tonnes or kilogrammes: | |
The undertaking shall disclose the following information on its total amount of waste from its own operations, in tonnes or kilogrammes: | |
The undertaking shall disclose the following information on its total amount of waste from its own operations, in tonnes or kilogrammes: |