The debate on the ‘Circular Economy’ is hotting up, as the Juncker Commission tries to work out what changes it is going to make to the existing proposal to make it ‘more ambitious’. CHEM Trust have already pointed out the importance of chemical regulation – in particular REACH – in cleaning up the circular economy. We’ve now joined with European Environmental Bureau (EEB), Friends of the Earth Europe and Zerowaste Europe, to produce a short position paper on the issue, entitled “The Circular Economy and REACH: An Essential Partnership“.
You can find the full details of our shared position in the two page position paper, but here are the headlines:
- A clean, effective and sustainable circular economy requires the removal of problematic substances from products at the design stage.
- Once recycled material re-enters the economy due to it receiving end of waste status, by complying with specific end of waste criteria or being incorporated in a new product, it must be fully compliant with chemical legislation.
- When a temporary exemption or authorisation has been granted to enable the continued presence of hazardous substances in products made from recycled material, the material should be labelled.
- Research and development of processes to remove hazardous substances from waste materials should be encouraged.
- Companies making products should be aware of the chemicals they are using, and which are likely to be restricted in the future, for example by using the SIN List.
- The claims made regarding the economic impact of REACH on recyclers, particularly SMEs, are not backed by good quality data.
In conclusion, the EU should focus on creating a clean circular economy, as without this there is a major risk of a future loss in public and market confidence in recycled material.