Circular Economy Action Plan falls short of its target
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Circular Economy Action Plan falls short of its target

“There is only one planet Earth, yet by 2050, the world will be consuming as if there were three”. That is the first sentence in the Circular Economy Action Plan that the European Commission presented last week.

The choice of opening phrase is understandable. The rate at which we’re spending the Earth’s resources is alarming and it’s clear to everyone that the “take-make-waste” approach of linear economy is no longer sustainable. It has actually never been sustainable, but it is only just now that we’re coming to terms with it. A clear sign of this was the green wave that swept in over Europe in the EU elections last year, setting the stage for the new EU Commission to develop the European Green Deal, which was presented in December.

For this reason, I rubbed my hands in anticipation when I sat down to read the Circular Economy Action Plan, hoping for clear and decisive measures. Especially on how to assure that a circular economy would be clean and free from hazardous chemicals.

After reading it, I felt… unsatisfied.

After that first sentence, it loses its edge. Even though the sense of urgency is there, it lacks the powerful measures that are necessary to fundamentally change the system and achieve a circular economy.

“It lacks the powerful measures that are necessary to fundamentally change the system”

For example, it states that the EU Commission will “provide incentives and encourage sharing of information and good practices in waste recycling”. It also states that the Commission will “co-operate with industry to progressively develop harmonised systems to track and manage information on substances identified as being of very high concern”.

This is absolutely fine, but more is needed. A lot more.

Tracking, assessing, analysing, informing, encouraging and so on, is not enough. What is needed are uncomfortable decisions. For example, instead of the Commission “considering reducing the complexity of packaging materials”, it should clearly state that there won’t be room for anything else in a circular economy, and follow this up with legislative proposals.

This would dramatically increase the recyclability of packaging materials because, unfortunately, not everything is as recyclable as it is made out to be.

Although most materials are recyclable in theory, you need the proper technology to be able to do it in practice. Since today’s technology can only really handle separated material streams, it means that complex materials in many cases are virtually unrecyclable.

“Legal requirements should
be put on the quality of the recycled content”

Restricting the number of packaging materials would therefore make it easier to maintain useable material waste streams and increase the recycled content.

And to increase the recycled content in products and materials is an aim that is mentioned several times in the action plan.

Now, just to be clear – I think this is great.

I am, however, concerned that too much emphasis is being put on the quantity of recycled content and not enough on the quality. Legal requirements on the amount of recycled content pave the way for lower chemical standards in order to meet a quantitative goal. To ensure that things are done right from the beginning, legal requirements should be put on the quality of the recycled content instead, making sure that it’s safe and non-toxic.

An important aspect of circular economy that is, unfortunately, missing completely from the action plan is chemical requirements on imported goods.

If a circular economy is to be free from hazardous substances, it is absolutely crucial that all products – whether they’re produced in the EU or imported into it – follow the same chemical standards. A growing number of imported goods from outside the EU means that there is a huge amount of material with unknown chemical content entering Europe, making safe recycling almost impossible. Yet, there is no mention of this issue in the action plan.

All in all, I think it’s great with an action plan based on the European Green Deal. I would, however, have liked to see a more ambitious one. Right now, it falls short of its target and leaves too many issues unaddressed.

When the EU Commission’s chemicals strategy is published in a couple of months, I will be rubbing my hands in anticipation once again, hoping to see a higher level of ambition.

theresa kjell

Theresa Kjell
Senior Policy Advisor at ChemSec