Difficulties in Waste Ecotoxicological Tests for HP14 Classification: Debate on Legislation and Test Challenges

Managing waste is one of society's greatest challenges! The shift underway in waste management is closely linked to EU legislation on the topic. Waste also represents an economic loss and burden to our society. There is a lot of debate about the legislation concerning hazardous waste classification. In fact, the requirements (in particular the ecotoxicological test batteries) for the HP 14 criterion (established by Regulation 2008/440/EC, the decision 200/532/CE and the Regulation 2017/997/EU) have not been fixed. The environmental data requirements and guidance used under the various different regulations cannot always be fully applied and the authorities in the various European Countries do not have a harmonized and precise method for HP 14 classification. In the absence of defined criteria, each experimental test can be carried out and evaluated according to the procedures established by the classification labeling and packaging (CLP) regulation, with many remaining issues regarding solution preparation and sample representativeness. Waste is a multi-component matrix and are therefore considered UVCB substances (substances of unknown or variable composition) with particular physical-chemical properties. Therefore, the preparation of solutions used for ecotoxicological assessment needs to be performed according to OECD 23, a guidance document on aquatic toxicity, testing of difficult substances and mixtures. Moreover, ecotoxicological concentration limits for classification of HP14 need to be clarified and defined among the various European Countries.