A new report on Circular Economy has been released by NGOs ClientEarth and EEB. The report describes the complexity of how REACH, product legislations, the Waste Framework Directive and specific waste stream directives interact and the implications this has on recycling.
In short, the report shows that environmental legislation is not an obstacle for circular economy; it is a prerequisite. To start with, hazardous substances should be avoided in products and legislation needs to get up to speed with scientific knowledge. The information flow of the hazardous contents also needs to be ensured. Finally it is crucial to keep recycled material to the same standards as virgin material to make it an attractive alternative to down stream users.
“This report is a much needed contribution the current discussion on circular economy in the EU, a topic that tends to be over simplified and not taking in all aspects needed to make circular economy the success that policy makers want to achieve”, says Theresa Kjell, Senior Policy Advisor at ChemSec.
“In order to increase reuse and recycling we must have information on what the material contains. If we can’t ensure that this material meets the same standards as virgin material, down stream users will not see it as an alternative. They must know that they deliver top quality to their customers. With increased traceability of the chemical contents of waste, this will be possible.”
To illustrate the consequences of different types of legislation on circular economy, the report uses two very different examples of products being recycled. One shows how a product containing hazardous substances (although being allowed in the product at the time of production), where the hazardous substances face reintroduction on the market due to interrupted information flow. The other case study looks into the recovery of products and waste covered by specific product and waste regulations. The hazardous components in these products can be removed and excluded from recycling as the information flow is transferred throughout the life cycle.