Certain chemicals found in products and materials make it more difficult to reuse and recycle these products – creating a challenge to ‘closing the loop’ in the circular economy. The European Commission plans to tackle this now by focusing on the interaction between chemicals, products and waste legislation.
The new policy paper from the European Commission, adopted at the same time as the Plastics Strategy in January 2018, presents a detailed analysis of the legal, technical and practical problems at the interface of chemical, product and waste legislation. These may be preventing the transformation of recycled materials into fit-for-purpose products that can be reintroduced into the productive economy.
We must make recycling easier and improve the uptake of secondary raw materials by promoting non-toxic material cycles.
Four major barriers to recycling and the creation of new products from waste streams have been identified. These include: insufficient information about substances of concern in products and waste; the presence of substances of concern in recycled materials and new products made from recycled materials; and difficulties in applying EU waste classification methodologies and impacts on the recyclability of materials.
For example, EU rules on the classification of waste as either hazardous or non-hazardous determine whether the holder of the waste needs to obtain a hazardous waste management permit. This, in turn, may affect the recyclability of the waste materials.
There are also many examples of problems with "legacy substances". The use of certain substances that were originally added to PVC to soften it are now regulated. This means that recycled PVC containing amounts of those substances above specific quantities should not be used or placed on the market in the EU.
Managing waste efficiently
Inconsistent application of these rules casts doubt on the legitimacy of waste-management practices for important waste streams containing substances of concern in materials such as minerals, plastics or glass.
Along with the results of new studies and ongoing evaluations, the Communication draws on the feedback from a targeted stakeholder consultation that took place in 2017 and provides further insights regarding the barriers to recycling.
The publication identifies options to facilitate recycling and improve the uptake of secondary raw materials (or recycled materials) through the promotion of non-toxic material cycles and better tracking of chemicals of concern in products. The options identified will feed into future work on a non-toxic environment.