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Chapter 09 — Wastes from the photographic industry Non-Hazardous

EWC Code

09 01

Wastes from the photographic industry

EUR-Lex Commission Decision 2000/532/EC — Official Journal L 226, 06/09/2000

Annual Volume

~50–100 kt/year photographic chemical waste (declining rapidly)

Valorisation Range

Silver recovery from fixer: €300–600/t silver content; X-ray film silver: €5–15/kg film

Primary Route

Silver recovery — electrolytic or metallic replacement

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Waste Classification

EWC 09 01 covers wastes from photographic film, paper and chemical processing — developer solutions, fixer solutions, bleach-fix residues and silver-rich sludges. Key hazardous codes: 09 01 01* (water-based developer and activator solutions), 09 01 02* (water-based offset plate developer solutions), 09 01 03* (solvent-based developer solutions), 09 01 04* (fixer solutions), 09 01 05* (bleach solutions and bleach fix solutions).

Silver is the primary value driver — photographic fixer solutions contain silver thiosulphate complex at 1–5 g/L; bleach-fix solutions at 2–8 g/L. Silver is recovered by electrolytic silver recovery units (ESRUs) at point of generation, metallic replacement cartridges or chemical precipitation. Spent fixer after silver recovery still contains thiosulphate and must be treated as hazardous waste — thiosulphate exerts significant COD on wastewater systems.

The photographic industry has collapsed in volume with digital imaging — medical X-ray remains the largest user, transitioning to digital radiography (CR/DR systems). Industrial NDT film use persists in weld inspection and aerospace. EU photographic chemical waste volumes have fallen >90% since 2000. Silver recovery is economically compelling where film/fixer volumes warrant — minimum viable electrolytic recovery at ~4 L/day fixer throughput.

Typical Generators

Medical imaging departments (X-ray film)
Photo processing labs (declining)
Industrial NDT and scientific film users

Disposal & Valorisation Routes

Established valorisation pathways for EWC 09 01, ranked by economic value and market depth. Silver recovery — electrolytic or metallic replacement is the primary route.

Silver recovery — electrolytic or metallic replacement

Primary

Fixer solutions processed through electrolytic silver recovery unit (ESRU) to plate silver on steel cathode. Depleted fixer re-used as starter fixer or treated as chemical waste. Metallic replacement cartridges (MRC) with iron wool reduce Ag⁺ to elemental silver — lower capital cost but less efficient. Silver bullion sold to refiner.

X-ray film silver recovery

Secondary

Processed X-ray film (silver halide-based) collected and sent to specialist recyclers — film emulsion stripped by alkaline hydrolysis or enzymatic treatment and silver recovered. PET film base recycled as plastic after emulsion removal. GDPR-compliant destruction of medical images required (shredding during processing or documented security procedure).

Chemical waste treatment and disposal

Backstop

Silver-depleted developer and fixer solutions treated by biological effluent treatment for COD, thiosulphate and ammonia. Thiosulphate oxidised by chlorination or activated sludge. Treated effluent discharged to sewer subject to trade effluent consent limits for silver (≤0.5 mg/L), COD (≤300 mg/L).

These are the established routes for EWC 09 01. Which one your stream qualifies for depends on its composition, volume and region.

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NACE Receiving Industries

Primary & secondary off-takers

01
Hospital activities

Medical imaging departments are primary X-ray film and fixer waste generators

02
Precious metals production

Silver refiners process X-ray film and fixer silver into bullion or silver compounds

03
Photographic activities

Remaining photo labs generate developer and fixer waste — declining rapidly

04
Technical testing and analysis

NDT film users (aerospace, petrochemical inspection) generate industrial X-ray film waste

Source: NACE Rev.2 — Eurostat, 2008

Regulatory Context

Key legislative frameworks governing EWC 09 01 classification, transport, and treatment.

Urban Wastewater Treatment Directive 91/271/EEC

Silver-containing photographic effluent classified as trade effluent. Discharge consent required. Silver limit: typically 0.5–2 mg/L Ag. Thiosulphate causes oxygen demand and interferes with biological treatment — pre-treatment required before sewer discharge.

GDPR Regulation (EU) 2016/679 — Medical image destruction

Medical X-ray films contain patient data. Film must be destroyed in a manner that renders images permanently unreadable before recycling. Chain-of-custody documentation from hospital to recycler required. Silver recycler must provide destruction certificate.

Directive 2008/98/EC — Photographic chemical hazard

Developer solutions (hydroquinone, metol) classified H301 (toxic if swallowed) and H411 (environmentally hazardous). Fixer solutions containing silver thiosulphate classified H400 (harmful to aquatic environment). Both require hazardous waste consignment notes for transfer.

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Industries That Use This Waste

Sectors that valorise EWC 09 01 as an input material or secondary raw material.

Explore EU waste flows — Waste Atlas

Visualise 17 years of E-PRTR industrial facility data. See how EWC 09 01 and related waste streams flow across European industries and sectors.

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Source: EUR-Lex Commission Decision 2000/532/EC · NACE Rev.2 — Eurostat 2008

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