Fact sheet Low POP Content Threshold
Introduction
Europe's WEEE stream contains significant quantities of plastics that can be recovered and returned to manufacturing. However, the presence of brominated flame retardants (BFRs), including substances regulated as persistent organic pollutants (POPs), creates specific requirements for the sorting and treatment of these plastics.
In 2022, EERA prepared this fact sheet during discussions on proposed changes to the Low POP Content (LPC) thresholds for PBDEs and HBCDD. It examined the implications of these thresholds for WEEE plastics recycling and explained the distinction between the LPC threshold applying to waste and the Unintentional Trace Contaminant (UTC) threshold relevant to recycled materials and articles.
It also examined WEEE plastics mass flows, BFR separation and density-based sorting, and considered how lower POP thresholds could affect recycling operations and investment in recovering additional polymers.
EERA called for a regulatory approach that combined the safe removal of restricted BFRs with the continued development of high-quality WEEE plastics recycling in Europe.
WEEE plastics and the European recycling market
The fact sheet estimated that approximately 11 million tonnes of WEEE were generated in the EU in 2020, with plastics accounting for around 25% of the total. These plastics include a wide range of technical polymers, such as ABS, polystyrene (PS), polypropylene (PP), polycarbonate (PC) and PC-ABS, as well as numerous additives including flame retardants, fillers, plasticisers and pigments.
EERA highlighted the potential contribution of WEEE plastics recycling to Europe's circular economy and recycled plastics objectives. Unlike virgin technical polymers, which depend on fossil resources and energy-intensive production, post-consumer recycled (PCR) polymers from WEEE originate from existing material streams and can be returned to manufacturing. The fact sheet presented WEEE plastics recycling as requiring less than 10% of the energy associated with virgin polymer production and estimated savings of around 3–4 tonnes of CO₂ per tonne of PCR material.
The fact sheet also identified changing BFR thresholds and the loss of WEEE plastics from official treatment channels as constraints on market development. EERA argued that regulatory uncertainty could discourage investment in European recycling capacity.
Expanding WEEE plastics recycling therefore depended on technology, access to sufficient feedstock and a stable regulatory framework.
Where BFR-containing plastics occur
WEEE contains a complex mixture of polymers and additives, including plastics with brominated flame retardants added to electrical and electronic products to meet fire-safety requirements.
Importantly, the fact sheet distinguished between BFRs generally and restricted POP BFRs. It stated that most BFRs present in WEEE plastics were permitted substances, while only a smaller proportion were restricted POP BFRs. It also noted that the use of the restricted BFRs in new electrical and electronic equipment had already ceased more than a decade earlier.
The distribution of BFR-containing plastics was not uniform across WEEE. Drawing on the SOFIES study, the fact sheet identified three principal WEEE categories where POP BFR-containing plastics were concentrated:
Displays and screens
Small equipment
Small IT and telecommunications equipment
Because BFR-containing plastics are concentrated in particular WEEE streams, effective sorting and separation are essential to remove restricted substances while retaining recyclable technical polymers.
WEEE plastics and BFR mass flows
The fact sheet estimated that approximately 2.6 million tonnes of WEEE plastics were generated annually in Europe, of which around 9% contained brominated flame retardants. However, only about half of all WEEE plastics generated entered official WEEE collection and treatment channels.
The mass-flow analysis, based on the SOFIES study, illustrated how plastics were distributed between official collection and treatment, complementary recycling, undocumented flows, waste bins and other destinations. According to the fact sheet, only around 22% of all WEEE plastics generated ultimately reached plastics recycling.
The picture was particularly significant for BFR-containing plastics. Around 220,000 tonnes of BFR-containing plastics were estimated to arise annually from WEEE, but only 45% entered official WEEE treatment channels. Of the BFR-containing plastics that did enter official recycling channels, the fact sheet reported that 98% were properly disposed of, while 55% of the total generated remained outside those official channels.
EERA used these figures to argue that directing more WEEE plastics into controlled European treatment systems was critical to managing POP BFRs effectively.
Understanding the LPC and UTC thresholds
The fact sheet distinguished between two regulatory thresholds affecting WEEE plastics recycling: the Low POP Content (LPC) threshold and the Unintentional Trace Contaminant (UTC) threshold. They concern POPs but apply at different stages of the material cycle.
The LPC threshold applies to waste. It determines how waste containing POP substances above specified concentrations must be managed and treated in an environmentally sound manner. The fact sheet stressed that exceeding the LPC threshold did not automatically mean that WEEE plastics were classified as hazardous waste for shipment purposes. It also linked environmentally sound treatment in the EU to the EN 50625 series of WEEE treatment standards.
The UTC threshold applies to substances unintentionally present in articles, including products manufactured from recycled materials. For post-consumer recycled plastics from WEEE, EERA therefore considered this threshold particularly important because it affected whether recovered plastics could be returned to the market.
The fact sheet also highlighted a practical issue with further reductions. WEEE plastics recyclers commonly used X-ray fluorescence (XRF) to screen for bromine, with the cited screening method validated at a threshold of 1,000 ppm bromine. EERA argued that lowering applicable limits beyond what available screening methods could reliably support would create significant practical difficulties for recyclers.
The distinction was central to EERA's argument: LPC governs the management of waste, while UTC determines the conditions under which recycled material can return to the market.
How WEEE plastics are sorted
WEEE plastics contain a complex mixture of polymers, additives and other materials. The fact sheet described density-based sorting, or “sink-float” separation, as a key process for producing relatively homogeneous WEEE plastic fractions with low BFR content that could subsequently be processed into recycled polymers.
Typically, the process involved two density-sorting stages. Lower- and medium-density fractions could be further separated to recover polymers such as PP, PE, ABS and HIPS with relatively low levels of additives. These were the density ranges in which the WEEE plastics recycling industry was already operating commercially at the time of the fact sheet.
The indicative composition presented in the fact sheet included 17% ABS, 14% HIPS, 12% PC and PC-ABS and 12% PP. Plastics containing BFRs accounted for 8%, while plastics containing restricted BFRs represented around 1%.
The higher-density fraction had traditionally been directed towards disposal, including incineration. However, EERA highlighted this fraction as an important area for future recycling development because it also contained potentially valuable technical plastics. New sorting technologies could enable recyclers to recover additional polymers from these heavier fractions rather than losing them from the material cycle.
Improved separation can therefore remove plastics containing restricted BFRs while increasing the quantity and range of WEEE plastics available for recycling.
EERA's key messages
The fact sheet summarised EERA's concerns about further reductions in POP BFR thresholds in five key messages:
Lowering the LPC threshold further could create inconsistencies with other EU chemicals legislation. EERA argued that the approach should be coherent with REACH and RoHS and with the EU's wider objective of consistent chemicals assessment.
Lower LPC thresholds could push more WEEE plastics into undocumented flows. The fact sheet warned that stricter limits could divert material away from controlled European treatment and recycling channels.
The relationship between LPC and UTC thresholds needed careful consideration. EERA argued that lowering the LPC below the UTC level could create pressure to reduce the UTC threshold as well, with direct consequences for recycled plastics placed back on the market.
Europe needed additional WEEE plastics recycling capacity. The fact sheet maintained that continued changes to POP thresholds could undermine the regulatory certainty needed for investment in new capacity.
Further reductions could constrain recycling innovation. EERA warned that lower UTC thresholds could make it more difficult to develop technologies for recovering additional polymer types from WEEE plastics and could potentially affect existing recycling capacity.
Overall, removing restricted POP BFRs and increasing WEEE plastics recycling should be pursued together, with thresholds that protect health and the environment while remaining technically workable for recyclers.
About the fact sheet
The Fact Sheet: Low POP Content Threshold was prepared by EERA in 2022 in the context of discussions on proposed Low POP Content thresholds for PBDEs and HBCDD.
Presented in a concise visual format, it addressed BFR mass flows, LPC and UTC thresholds, density-based sorting and the implications of lower thresholds for recycling capacity and innovation.
The fact sheet reflects EERA's position and the regulatory discussions at the time of publication and should therefore be read in its 2022 policy context.
View the original fact sheet
View the original Fact Sheet: Low POP Content Threshold for the underlying figures, diagrams and EERA's 2022 key messages on POP BFR thresholds and WEEE plastics recycling.
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