On April 22, 2015 the advocacy group for chemical safety CHEM Trust announced it had joined forces with the European Environmental Bureau, Friends of the Earth Europe and Zerowaste Europe to produce a position paper entitled “The circular economy and REACH – an essential partnership”. The non-governmental organizations (NGOs) stress that the interaction between product, waste and chemicals legislation is a key aspect of the circular economy. In Europe, once an item becomes waste, it is exempted from the European chemical regulation REACH. However, issues arise when discarded products, to be reprocessed, contain substances which have since been restricted or otherwise controlled through REACH. This creates a legacy that recyclers and converters have to deal with in order to create a safe product compliant with REACH regulations.

The main burden for recyclers is, however, not REACH and the chemical policy, but the actual presence of hazardous substances in the materials. The NGOs thus suggest that the EU should focus on removing hazardous substances from products and waste. Ideally, problematic substances would be removed from products at the design stage (“source control”). This requires a stronger application of REACH, according to the NGOs.

Furthermore, the EU shall stop endangering the environment and public health by “exempting certain classes of businesses or products from safe requirements and making it impossible to identify contaminated materials in the future.” In the cases when a temporary exemption or authorization has already been granted to enable the presence of hazardous substances in products made from recycled material, the material should be labelled, the NGOs propose.

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CHEM Trust (April 22, 2015). “CHEM Trust joins with other NGOs to highlight the importance of REACH to the Circular Economy.

CHEM Trust (April 22, 2015). Position paper “The circular economy and REACH – an essential partnership(pdf)