In a press release published on February 10, 2020, the European recycling association EuRIC AISBL announced the publication of a position paper on the sound management of waste and chemicals for the circular economy. The paper “highlights the main issues derived from the lack of interface between chemicals, product and waste legislation, and identifies simple solutions to boost the transition towards a more circular economy.” Specifically, it discusses the challenges recyclers face in being able to control the presence of hazardous substances in the materials they recycle.

To address this, the paper provides a set of recommendations including: (i) better enforcement of chemicals legislation at EU borders on imported products, (ii) developing a regulatory framework to track hazardous substances in products, (iii) applying a risk-based (and not hazard-based) approach for classifying wastes, (iv) harmonizing waste legislation across all EU member states, (v) creation of rules specifically for secondary materials that provide derogations (potentially time limited) for legacy substances recently restricted in new products, (vi) removing hazardous substances during the design phase of products (instead of holding recyclers responsible for their presence in recycled materials).

In comments made to regulatory news provider Chemical Watch, the European Chemicals Agency (ECHA) said that enforcing EU regulations on imported products at the border can be difficult when products are manufactured with substances of very high concern (SVHCs) but do not actually contain them. The agency noted that imported products containing SVHCs will, however, be a key focus for its enforcement activities in the next two years. Regarding the proposed exemptions for legacy chemicals in recycled materials, the non-governmental organization European Environment Bureau commented that the EU should “avoid reinjection [of hazardous chemicals] in the economic cycle, even if to start with this may limit recyclability of contaminated material, that can then be burnt in specific incinerators from which heat recovery could be considered.”

Read more

EuRIC AISBL (February 10, 2020). “EuRIC unveils brochure on the safe management of chemicals by the recycling industry.” (pdf)

Leigh Stringer (March 4, 2020). “Imported products must meet EU chemicals legislation, says recycling body.” Chemical Watch

Sustainable Plastics (June 4, 2020). “Plastics recycling is key to the circular economy, says EuRIC.”


EuRIC AISBL (February 10, 2020). “Sound management of waste & chemicals requirements by the recycling industry.” (pdf)