In an article published on July 11, 2017 by environmental news and information service ENDS Europe, José Rojo discussed the responses submitted by industry and NGOs to the EU consultation on the interface between chemicals, products, and waste legislation, which closed on July 7, 2017. The consultation was carried out in conjunction with the roadmap on the same topic, published by the European Commission (EC) in January 2017.

The European Federation of Waste Management and Environmental Services (FEAD) maintained that chemical compliance can be harder to reach for recyclers as they may have to deal with legacy substances. However, even those recycling materials that contain toxic substances may have “environmental and economic benefits” outweighing those of virgin materials. Therefore, FEAD said that information on the presence of substances of very high concern (SVHCs) should be openly shared between suppliers, but “the need to restrict their use should be decided on a case-by-case basis,” as some substances may have “’insignificant’ environmental and health risks.”

A different view was expressed by the NGO CHEM Trust in their response, requesting that SVHCs in recycled materials be treated equally to those in virgin materials. CHEM Trust drew attention to contamination issues in paper packaging made of recycled paper (FPF reported) and in toys made of recycled plastic (FPF reported), saying that these examples illustrate that “regulatory gaps […] mean that ‘polluter pays’ principle is not respected.” CHEM Trust maintains that, if the EU is to move to a circular economy model, the use of hazardous chemicals should be restricted to a minimum (FPF reported).

Further, FEAD called for the introduction of end-of-waste criteria. However, CHEM Trust “cautioned that establishing end-of-waste status could be ‘problematic’ for waste streams such as plastics, where the contamination of recyclates is an issue.”

Read more

José Rojo (July 11, 2017). “Chemicals in the circular economy divide experts.ENDS Europe

CHEM Trust (July 7, 2017). “European Commission stakeholder consultation: ‘Chemical, product, waste interface.’ Response from CHEM Trust, 7th July 2017.” (pdf)

Chemical Watch (February 2, 2017). “European Commission launches chemicals and waste roadmap.

EC (January 21, 2017). “ROADMAP. Analysis of the interface between chemicals, products and waste legislation and identification of policy options.” (pdf)

EC (January 27, 2017). “Stakeholder consultation paper. Chemical, product, waste interface.” (pdf)