In an article published on August 21, 2018, by the non-profit organization International Chemical Secretariat (ChemSec), Jerker Ligthart, the organization’s senior chemicals advisor, argued that regulators often focus too much on prioritizing hazardous chemicals rather than actually dealing with them. Under REACH, “[i]n over ten years’ time barely 200 substances have been included on the Candidate List” of substances of very high concern (SVHCs), he highlighted. “[P]prioritization should never mean that some chemicals are never dealt with,” and there should be “a strict timeline” for action, he added.

To make the circular economy a reality, hazardous chemicals need to be considered, Ligthart further stressed. “Basically, such [hazardous] substances can’t be included in any products that are about to be reused, recycled, or up-cycled,” he stated. Because of the “endless possibilities for future exposure” in a circular economy, substances’ intrinsic properties need to be considered rather than “solely looking at potential exposure and the current use of a certain chemical,” Ligthart suggested. To address more than one chemical at a time, substances should be grouped according to their structural similarity to substances with known hazardous properties, whereat a “substance should be considered as hazardous until proven harmless,” he further recommended. “If we want to achieve a true circular economy, the answer is to prioritize the removal of hazardous substances in the first place, not to discuss which ones are the most urgent ones,” Ligthart concluded.

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Jerker Ligthart (August 21, 2018). “How a hazard-based approach and grouping of chemicals can pave the way for circular economy.ChemSec