19
Accelerating Wind Turbine Blade Circularity - 2020
WindEurope – Cefic - EuCIA
Legislative context
, the PV Cycle Distributor Take-back Scheme
(DTS) has received full government accreditaon, enabling
UK Distributors (i.e. any organisaon selling PV panels for
private households) to carry out their collecon and recy-
cling obligaons with a comprehensive support system at
reasonable cost. This means any distributor must have a
procedure in place to take back PV waste. Distributors can
choose to set up their own free take-back operaon or
join the PV CYCLE Distributor Take-back Scheme.
In other industries, EPR is taken into account by use of
Environmental Product Declaraons (EPD). These decla-
raons provide informaon on material composion and
life cycle assessment, and can also provide dismantling in-
strucons and recycling opons. For example, the use of
EPD is established in the building and construcon sector.
There is a European Standard describing the ‘core rules’
for these documents (UNE EN 15804:2012+A1:2014 Sus-
tainability of construcon works – Environmental product
declaraons – Core rules for the product category of con-
strucon products).
In France and Germany EPR for the wind industry has
been discussed (see country case studies below). In gen-
eral, wind turbine blades are very large structures and
therefore, unlike baeries, computers and PV panels, they
are unlikely to become mixed with local/municipal waste
streams. This is already recognised in the WEEE Direcve
where wind turbines are excluded because they are con-
sidered ‘Large Scale Fixed Installaons’.
the Ministry for a Just
and Ecological Transion commissioned a study on
wind turbine circularity. The report, published in
October 2019, recommended introducing EPR for
blades
[16]
. EPR responsibilies already exist in 14
sectors including end-of-life vehicles, end-of-life
ships, tyres and unused medical drugs.
The new law on circular economy adopted on 10
February 2020 extended EPR responsibilies to new
products such as toys, cigarees, texles for health-
care and building materials. Wind turbine blades
were not included in this new list. It was deemed
that EPR for wind turbine blades would not be ef-
fecve in increasing blade recycling. Instead, joint
eorts between authories and the industry were
deemed more likely to be successful.
UBA, the Federal En-
vironment Agency, commissioned a study on wind
turbine decommissioning and waste management.
Results from the study formulate recommendaons
for the set-up of an ecient dismantling system in
Germany
[3]
. This assumes among others to poten-
ally include specic elements of product responsi-
bility for Original Equipment Manufacturers (OEMs)
including:
• “Informaon and labelling obligaons re-
garding the material composion of the rotor
blades;
• Separate processing with the aim of quality as-
surance of recyclates and substute fuels;
• Obligaon for high quality recycling or guaran-
tee of disposal safety;
• Inclusion of manufacturer’s knowledge and
processing technologies adapted to prod-
uct-related technological change; and
• Cause-related allocaon of disposal costs and
organisaonal obligaons during disposal”.
However, the report also highlights the following
challenges speaking against the introducon of a
specic product responsibility for rotor blades:
• “Many wind turbine manufacturers are acve
across Europe. An isolated regulaon in Ger-
many is possible but is at odds with the funda-
mental idea of EU internal market;
• Format and storage locaon (manufacturer,
operator, authority) as well as compeon rel-
evance of the data collected;
• Long service lives of rotor blades are an obsta-
cle to an individual product responsibility; and
• The discussion on disposal opons for [glass
reinforced polymers/carbon reinforced poly-
mers] also extends to other products made of
such materials and may have to be addressed
more specically for materials ows than for
products”.
Currently, there is no iniave for legislaon in Ger-
many related to this issue. UBA is commissioning
another study on the “development of decommis-
sioning and recycling standards for rotor blades”.
The study will start in 2020 and run for 20 months.