Confindustria Emilia-Romagna

1. Confindustria Emilia-Romagna REGULATORY ASSESSMENTON THE ENVIRONMENTAL VIABILITY OF SOREME SORBENT (B.5) SOREME Project Estonia, 18-20 June 2014 Life+ 11 ENV/IT/109-SOREME

2. INTRODUCTION-SOME KEY FIGURES ON PRODUCTION AND REUSE OF USED TYRES (UT) IN EUROPE • 355 MIO IS THE ANNUAL PRODUCTION OF TYRES IN EUROPE – WHICH CORRESPONDS TO 24% OF THE WORLD PRODUCTION • IN 2011 ABOUT 3,2 MIO TONS OF TYRES REACHED ENDLIFE • APART FROM THE SHARE ALLOCATED TO REUSE, EXPORT AND RECONSTRUCTION, 95% STARTED SOME RECOVERY PROCESSES, THUS CONFIRMING EUROPE AS ONE OF THE TOP PERFORMING AREAS IN USED TYRES RECOVERY • IN 2013 IN ITALY ALONE, 35 MIO OF OLD TYRES REACHED ENDLIFE (340 THOUSAND TONS) • 2/3 STARTED RECOVERY OPERATIONS. USED TYRES CONVERTED INTO ENERGY PRODUCTION IN 2013: 30% CONVERTED INTO FUEL FOR ELECTRIC ENERGY PRODUCTION; 70% CONVERTED INTO FUEL FOR CEMENT FACTORY FURNACE • OTHER KNOWN RECOVERY APPLICATIONS ARE a) ROAD CONSTRUCTION, ACOUSTIC PANELS AND BARRIERS, ANTISISMIC COMPONENTS, PAVEMENT OF ATHLETIC AND RECREATIONAL AREAS; b) FASHION, IN PARTICULAR IN SHOES PRODUCTION c) INTERIOR DESIGN

3. RECOVERY PRELIMINARY PROCEDURES • IN ORDER TO BE RECOVERED, USED TYRES (UT) HAVE TO BE PROCESSED • FIRST, THE STEEL WHEEL/RIM WHICH MAKES UP THE CIRCULAR DESIGN OF THE TYRES IS REMOVED (AND IN TURN IT IS RECOVERED IN THE STEEL INDUSTRY/FOUNDRY) • SECOND, THE UT ARE SHREDDED INTO CHIP AND SHREDDED TYRES RANGING FROM 5 AND 40 CM • THIRD, THE SHREDDED TYRES CAN BE FURTHER SIZE-REDUCED AND DIVIDED INTO: RUBBER, STEEL AND TEXTILE • THE RUBBER IS FURTHER SHREDDED AND TRANSFORMED INTO GROUND AND CRUMB RUBBER, WHICH CAN BE USED IN DIFFERENT WAYS (FROM THE BUILDING INDUSTRY TO THE ROAD CONSTRUCTION INDUSTRY – DRAINING ASPHALT/BITUMEN) • THE CHALLENGE OF THE SOREME PROJECT IS TO PROVE THE EFFICIENCY OF THE USE OF CRUMB RUBBER (CR) AS MERCURY ABSORBER (AS AN ALTERNATIVE TO ACTIVE CARBON)

4. THE TURNOVER ESTIMATED TURNOVER GENERATED IN ITALY FROM REUSED TYRES: 120-130 MILLION OF EURO PER YEAR

5. THE LAW ON UT RECOVERY • THE LATEST EUROPEAN DIRECTIVE, 2008/98/CE, INTRODUCED SEVERAL CHANGES FIRST, NEW DEFINITIONS HAVE BEEN INTRODUCED: • RECOVERYmeans any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfilL a particular function, or waste being prepared to fulfill that function, in the plant or in the wider economy • RECYCLING: means any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations • RE-USE: means any operation by which products or components that are not waste are used again for the same purpose they were conceived FOR.

6. SECOND, THE INTRODUCTION OF THE NEW DEFINITION OF “END OF WASTE” AS WASTE THAT HAVE TO BE PROCESSED ACCONDING TO OPERATIONS HAVING SPECIFIC REQUIREMENTS: • IT HAS TO BE A MATERIAL WHICH IS COMMONLY USED; THERE HAS TO BE A MARKET, THAT MEANS A DEMAND FOR IT; IT HAS TO MEET TECHNICAL REQUISITES FOR SPECIFIC TARGETS, AND LAST BUT NOT LEAST IT DOES NOT HAVE TO GENERATE NEGATIVE IMPACTS ON THE ENVIRONMENT AND HUMAN HEALTH • FOR SOME OF THESE WASTE CATEGORIES, INCLUDING TYRES, THE DIRECTIVES ALLOWS FOR THE DEFINITION OF EUROPEAN CRITERIA TO DETERMINE WHEN A WASTE (LIKE THE UT) IS NO LONGER TO BE CONSIDERED A WASTE • IF NO SUCH CRITERIA EXISTS AT A EUROEPAN LEVEL, EACH MEMBER STATE CAN DECIDE CASE BY CASE • IF SO, THE MEMBER STATE HAS TO NOTIFY THE NATIONAL PROVISION TO THE EU

7. THE ITALIAN EXPERIENCE • DIRECTIVE 2008/98/UE HAS BEEN IMPLEMETED IN ITALY WITH THE LAW D.LGS 205/2010 MODIFYING THE PRE-EXISTING LAW D.LGS 152/06 • ART. 228 FORCES THE TYRE MANUFACTURERS TO SET UP A UT MANAGEMENT SYSTEM (ALSO IN COOPERATION) AND IT REFERS TO 2 LAW APPLICATIONS • THESE APPLICATIONS HAVE BEEN ADOPTED BY NATIONAL LAW D.M. 82/2011 AND D.M. 44/2012 • ART. 184 TER REFERS TO A SUBSEQUENT LAW WHICH REGULATES THE DEFINITION OF RECOVERY ACTIVITY RESULTING IN THE WASTE TO BE CONSIDERED “END OF WASTE” • THIS LAW HAS NEVER BEEN ADOPTED AND ACCORDING TO THE CONTINUITY PRINCIPLE THE EXISTING LAW D.M. 5 FEBBRAIO 1998 IS STILL IN FORCE

8. CONCLUSION • IN ITALY A NATIONAL LAW, THAT DEFINES THE CRITERIA ACCORDING TO WHICH A UT CAN BE EXCLUDED FROM THE WASTE CATEGORY IF RECYCLED, HAS NOT BEEN ADOPTED • IN EUROPE TOO, IT LACKS SUCH A LAW DEFINING THE OVERALL CRITERIA ACCORDING TO WHICH A UT COULD BE EXCLUDED FROM THE WASTE CATEGORY IF USED IN SPECIFIC ACTIVITIES, SUCH AS THE TRANSFORMATION INTO CRUMB RUBBER FOR FILTERS TO ABSORB MERCURY EMISSIONS • IN ORDER TO DEFINE SUCH A LAW, IT IS NECESSARY TO EVALUATE AND REGULATE WHICH ARE THE IMPACTS ON THE ENVIRONEMENT GENERATED BY THE DISPOSAL OF THESE NEW DUSTS • SECONDLY, IT IS NECESSARY TO EVALUATE WHICH ARE THE IMPACTS ON THE ENVIRONMENT AND THE HEALTH GENERATED BY EMISSIONS OF THE PLANTS USING THE FILTER WITH CRUMB RUBBERS (THUS THE SOREME PROJECT AND THE RELATED MANUFACTURING APPLICATIONS)

9. CONCLUSION • THE APPROVAL OF ONE EUROPEAN ACT ON THE UT RECOVERY FORMS, INCLUDING THIS RECYCLING FORM, MIGHT HAVE NUMEROUS AND SIGNIFICANT ADVANTAGES: • RECOVERY OF UT THROUGH A NEW RECYCLING FORM RESULTING IN ADVANTAGES AND ENVORNMENTAL SAFEGUARDING • HIGHER TRACEABILITY LINKED TO THE RECOVERY OPERATIONS • LOWER AIR EMISSION OF MERCURY • SAFEGUARDING OF THE ENVIRONMENT AND THE PEOPLE’S HEALTH • CERTAINTY ABOUT THE RESPECT OF LAWS BY THE OPERATORS RESULTING IN A DECREASE OF LITIGATIONS WITH THE AUTHORITIES AND THE CITIZENS • LOWER COSTS FOR UT RECOVERY

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