In an article published on May 13, 2020, regulatory news provider Chemical Watch writes about the needs and concerns the recycling sector and non-governmental organizations have in regards to the EU’s recently announced circular economy action plan (CEAP) (FPF reported). The European Commission (EC) recently announced a set of interlinked action plans, strategies, and databases that each aim to address the presence of hazardous substances in wastes – a growing topic of discussion over the past few years.

The currently separate waste and chemicals policies in the EU are being seen as a key complication in the approach to address the issue, and recyclers are calling for improvements and clarifications. Emmanuel Katrakis, secretary general of the European Recycling Industries’ Confederation (EuRIC) said that “the current lack of interface between products, chemicals and waste legislation remains a stumbling block in many instances for the recycling industry.” EuRIC recently published a document outlining the top five priorities for the recycling industry through 2024. In March 2020, the organization also published a document outlining requirements for the sound management of waste and chemicals as seen by the recycling industry (FPF reported). In addition, Katrakis commented that he believes assessments should take into account the exposure routes of substances as well as their compositional hazards in order to avoid misclassification. The EC commented that it expects to carry out a study investigating the impacts on potential changes to the waste classification rules within the EU at the end of 2021 or in early 2022.

One of the goals within the CEAP is the development of a harmonized information system to keep track of the life cycle of substances of concern and identify when they are present in waste. Achieving this will start with a feasibility study by the EC to investigate tools and software applications to track substances, and it also aims to support future actions in the context of the EC’s upcoming chemical strategy (FPF reported). The European Chemicals Agency (ECHA) is further launching a database to track substances of concern in products (FPF reported), and the EU recently revised regulation specifically on persistent organic pollutants to remain aligned with requirements of the Stockholm Convention. The EC is also reported to be considering expanding the scope of its Ecodesign Directive (2009/125/EC) to include toxic chemicals in products.

With a growing number of commitments and regulatory requirements for recycled content in products, stakeholders are emphasizing the importance of maintaining the quality of recycled materials as the demand for them increases. Theresa Kjell from non-governmental organization ChemSec said “we strongly support recycling but not at any cost. We need to stay with a high standard of material, making sure that it is safe and non-toxic.” One outstanding issue multiple stakeholder groups see in the current CEAP is a failure to address requirements on products imported into the EU, which have unknown chemical contents and will eventually end up in local waste systems.

A recent report published on May 14, 2020, by the Dutch National Institute for Public Health and the Environment (RIVM) also addressed the issue of chemical safety in the circular economy. The country aims to have a “completely circular economy” by 2050, and it specifies that “substances of high concern, like those causing cancer for example, will only be used in materials and products when there are no known alternatives and their use is considered essential for the functioning of society” and further that these substances “must not be released during production, use or re-use.” The report identifies three challenges in transitioning to a circular economy including (i) the necessity to share information about substances used throughout the product chain, (ii) the need for members of the product chain to consider the safety of re-using their products already during the design phase with product users and governments also contributing, and (iii) the importance for everyone involved to act responsibly in regards to products containing substances of high concern that do not have an alternative.

To address these challenges, the report provides a set of recommendations including shorter- and longer-term actions. In the shorter term, RIVM sees “the need to develop a policy vision and interim goals and to prioritize those products, materials and substances for which there is an urgent need to realize safe and circular product chains.” In the longer term, it believes that recommendations need to be reconsidered and adjusted to adapt to the changing demand for substances and also that monitoring should be carried out to ensure that the reuse and recycling of products containing substances of high concern are conducted safely. Overall, the report describes itself as aiming to “offer some guidance and help to set an agenda for further debate between governments, companies, NGOs and research centers.”

Read more

Elaine Burridge (May 13, 2020). “Feature: What does industry think of the European Commission’s safer recycling plans?Chemical Watch

EuRIC (2019). “Top 5 Priorities of the Recycling Industry for the Period 2019 -2024.”

RIVM (May 14, 2020). “Coping with substances of concern in a circular economy.” (in Dutch)

Chemical Watch (May 20, 2020). “Information exchange key to handling SVHCs in circular economy – Dutch report.”

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