The EA has issued both a Regulatory Position Statement and Guidance LIT 72733 – Glass from waste treatment facilities (002) in relation to glass that has been sorted from mixed recyclables at MRFs.
In effect, they are saying that in line with other materials, sorted glass can only be counted as 19 12 05 if it contains minimal contamination and in their opinion, this is unlikely to be achieved through normal sorting of household recyclable waste at MRFs. This therefore means that the sorted glass and other materials that do not meet the ‘minimal contamination’ threshold should be classed as either 19 12 11* or 19 12 12 – mechanically separated waste, either hazardous or non-hazardous. The classification then needs to be determined by a WM3 assessment.
This has a significant impact. 19 12 11/12 code waste would need to be exported under notification although if 19 12 11*, the export would be banned to non-OECD countries. And many storage and processing sites do not have 19 12 11/12 on their permits. RPS 292 allows sites with 19 12 05 on their exemption or permit to accept 191 12 12 (non-hazardous) under specific conditions so long as they inform the EA. The RPS will be reviewed in May 2025.