ECO-INNOVATIONat the heart of European policies
Denmark's Environmental Protection Agency (EPA) published at the end of March 2016 the results of a study to define a methodology for identifying whether hazardous chemicals in products make it difficult to recycle those products (Kemiske stoffer i forbrugerprodukter, der kan hindre genanvendelse, ‘Chemical substances in consumer products that could prevent recycling’). The study was carried out as part of Denmark's Chemicals Initiatives 2014-2017, which is an agreement between all of Denmark's political parties to reduce exposure to toxic chemicals1.
The presence of hazardous chemicals in waste has also been identified by the European Commission as an obstacle to the development of markets for secondary raw materials. The Commission's Circular Economy Action Plan, published at the end of 2015, noted that “chemicals of concern can sometimes be found in recycling streams. Such substances can be costly to detect or remove, creating obstacles in particular for small recyclers”2. The Commission said it would consider measures to “decide the right course of action at EU level to address the presence of substances of concern, limit unnecessary burden for recyclers and facilitate the traceability and risk management of chemicals in the recycling process.”
In this context, the Danish EPA answered some questions about its study on hazardous chemicals that could prevent the recycling of consumer products, and what applications the research could have.
In what types of products is the presence of hazardous chemicals the biggest problem for recycling? Your study focused on clothing and electronic goods. Are these the product types policymakers should give the greatest priority to for phasing out certain chemicals?
The overall aim of the project was to develop a method for describing and assessing whether, chemical substances contained in consumer products prevent recycling of the materials used in the products, or prevent recycling of other materials in the waste fraction where the consumer products end up after disposal. .
We started with a wide-ranging list of consumer products and selected nine product types for a general assessment. An expert workshop identified four analytical parameters for prioritising product types: 1) Problematic substance content; 2) Waste characteristics and volumes; 3) Recycling opportunities and technical possibilities for recycling; and 4) The market interest for the potentially recycled material. This helped us to choose two product types (outdoor clothing, and plastic parts from electrical and electronic products) from the nine initial product types.
Some of the substances you mention in the recycling study (phthalates, brominated flame retardants) are already controlled under EU legislation. Are there loopholes that still allow these substances in products?
In general, many uses of the most problematic phthalates now finally seem to be coming to an end – of course depending on the fate of the restriction proposal prepared by the European Chemicals Agency in collaboration with us. [Editor’s note: a wide-ranging restriction on phthalates in consumer products is currently under consideration under REACH, the EU regulation on the registration, evaluation and authorisation of chemicals]. However, problematic phthalates may still be present in products that are already in use, and when they are disposed of, these substances may still be present in recycled material for decades to come. As regards the per- (and poly-) fluorinated chemicals, only very few of them are currently subject to regulatory measures. Thus, we can expect to find these substances in recycled materials for many years.
Only the most hazardous brominated flame-retardants (BFRs) are subject to restrictions today. However the possibility of BFRs being present in plastic in electronics is the reason why plastic from electronics is (hardly) never recycled. The problem is made more difficult by the use of other BFRs, which detectors cannot distinguish from the restricted BFRs, because it is only bromine that is detected.
Do you think the methodology you have developed could be applied across the EU? Do you have any plans to translate the methodology or carry out other outreach activities – workshops for authorities in other countries, for example?
Maybe. It could be possible in the future but for the moment we have no plans regarding that. However, we would of course be happy to make a presentation for interested stakeholders.
Should recycling be taken into account in, for example, REACH restrictions? In other words, should REACH be used to ban certain chemicals from products that could be used to produce high-value secondary materials?
REACH restrictions are one option that can be used when a risk that is not controlled has been identified. This can also be extended to risks in the recycling stage. The main problem is that if, for example, a substance of very high concern is used in a certain type of product where no risk has been identified, the substance may end up in recycled material and being used for other types of products than originally intended, and for which risks might not necessarily be properly controlled.
How will the Danish EPA now apply this methodology?
The methodology will be applied in the Danish EPA’s consumer product efforts when it is considered relevant.
The study, Kemiske stoffer i forbrugerprodukter, der kan hindre genanvendelse, is available (in Danish with an English summary) at http://www2.mst.dk/Udgiv/publikationer/2016/03/978-87-93435-51-3.pdf
2‘Closing the loop - An EU action plan for the Circular Economy’, COM (2015) 614 final.