New operation R15 “co-processing” to Annex IV of the Basel Convention

BACI presented to MOEW some questions and answers prepared by the European Cement Association, CEMBUREAU, related to the addition of a new operation R15 “co-processing” to Annex IV of the Basel Convention.

The cement industry, represented by CEMBUREAU, offers an effective waste management solution that avoids landfilling or incineration, thus closing an existing gap in the circular economy.

  1. Why the new operation R15 “co-processing” is necessary?
    Today, some authorities classify the same co-processing operation as a combination of the different operations such as R3, R1, D10, R4, R5 or as a single operation. These variations create troubles and uncertainties when a notification is sent to authorities having a different opinion on the operation to apply.
    The new operation R15 “co-processing” is necessary in order to classify everywhere under a single code the simultaneous material recycling and energy recovery that happens when waste is co-processed like in cement plant or other industries.
  1. What is the definition of co-processing?
    Co-processing is defined as the combination of simultaneous material recycling and energy recovery from waste in a thermal production process. This results in replacing natural mineral resources and fossil fuels such as coal or petroleum products. In 2017, the European cement industry has used around 21 million tonnes of pre-treated waste and biomass for substituting the natural resources and for supplying the thermal energy to the clinker making process, following an increasing trend and an increasing future prospective.
    Adding the operation R15 “co-processing” to annex IV will promote further recycling of waste in cement kilns and other sectors. This will reduce the reliance of fossil fuels and minerals and be in line with the Paris Agreement for the climate change and the carbon-neutral vision for 2050.
    Provided a simultaneous material recycling and energy recovery from waste in a thermal process, other industrial sectors may also use R15 for their waste shipments, such as brick production, steel sector, etc
  1. How the new operation R15 “co-processing” will improve clarity?
    The new operation R15 “co-processing” will improve clarity, since the cement plants operators and other coprocessing industries will need to declare a single operation instead of a combination of operations for waste shipments. Additionally, the new operation will enhance simplicity and release users and officials from an unnecessary administrative burden.
  1. What the predominant operation or primary contribution of “co-processing” is?
    In the cement clinker making process both material recycling and energy recovery occur at the same time. This simultaneous process in the cement kiln sees the organic component of the waste heat the rotary kiln and the mineral elements of the waste become part of the cement clinker. This means that co-processing results in no residue materials, like ash. Therefore, someone cannot clearly define a predominant operation or a primary contribution of a waste.
  1. Is R15 “co-processing” in agreement with previous guidelines?
    The new operation R15 is in full agreement with the Basel Convention Technical guidelines on the environmentally sound co-processing of hazardous wastes in cement kilns, where the combination of the categories R1 and R5 is noted:
    “16. Co-processing wastes serve a useful purpose in replacing materials that would have otherwise been used in cement manufacturing, thereby conserving natural resources. Under the Basel Convention this constitutes an operation “which may lead to resource recovery, recycling, reclamation, direct reuse or alternative uses” under categories R1 (“use as a fuel or other means to generate energy”) and/or R5 (“recycling/reclamation of other inorganic materials”) of part B of Annex IV to the Convention.”