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Chemical safety in a circular economy

Currently, most of the products on the market get discarded after their use. They end up in landfills or are incinerated. This has to change. As our society slowly but steadily transitions towards a circular or closed-loop economy, the objective becomes to retain materials for as long as possible, reusing and recycling materials to minimize waste and reduce the need for additional resources.

The advantages of a circular system are clear: reducing pressure on the environment, securing the supply of raw materials, stimulating innovation, and boosting economic growth as well as creating jobs.

Although everyone is in favor of a higher degree of recycling, in practice it is not that simple. One of the big issues that many forget but is important to realize is that there are many (restricted) chemicals of concern currently present in products in our homes and offices, in furniture, electronics, plastics, etc. When articles are recycled, these substances may remain unidentified and are re-introduced on the market in various recycled products.

For a circular economy to be successful it is essential that customers are confident in the quality and safety of the recycled materials. If due to a lack of information on hazardous chemicals or due to the absence of clear regulatory control, this confidence is removed it is likely that the market will demand virgin materials and the progress toward a circular economy will be seriously hampered.

Unfortunately, in recent years this was the case. Several “scandals” have reached the mainstream media reporting of potentially unsafe levels of hazardous substances as a result of overlooking the hazard profile of recycled materials.

A well-known example is the rubber pellets used on artificial turfs made from recycled car tires.
When the rubber granulates were introduced, it was presented as a very environmentally friendly solution for the staggering number of waste tires. However, in October 2016 the Dutch television program Zembla reported on the risk of potential health effects due to the presence of hazardous substances in these types of rubber. Although it was well known that these substances are present in car tires, the potential exposures during this new use (dermal contact on the football field) were inadequately assessed beforehand.

Other examples include the presence of Substances of Very High concern (SVHC) in pizza boxes made from recycled cardboard and the presence of hazardous flame retardants which were once used in electronics found to be re-introduced on the market in plastic toys for children.

Although in many of these cases, the risk of detrimental effects on humans or the environment was found to be minimal after further investigation, the reputational damage was considerable.

Applicability of regulations

Driven by the need to reduce the use of raw materials and encouraged by national and international programs, the interest in the reuse and recycling of products has increased very fast. Not surprisingly, current legislation on waste and the use of chemicals is often not clear on how to assure the safe handling and use of recycling materials.

In order to stimulate the European transition towards a circular economy, REACH does not apply the same level of scrutiny to recycled materials as that virgin materials. For example, Cadmium is exempted under REACH for use in certain applications of recycled PVC, and recyclers can benefit from recycling privileges such as the exemption from registration when they put their recycled product on the market. If this is the kind of regulation that should be pursued is still a hot topic for political debate.

Regulations for food packaging in Europe do require the same level of safety for chemicals migrating into foods for all recycled and virgin materials alike. In Europe, the use of recycled plastics in food contact materials (FCMs) is specifically regulated under the Plastics Recycling Regulation (EC 282/2008). Unfortunately, in Europe, no harmonized regulation exists for other types of materials such as metals, glass and (recycled) paper FCMs. Some EU Member States have introduced their own specific measures creating additional confusion. Due to a lack of control, the use of recycled paper and board for direct contact with food has been banned in certain countries out of concerns regarding the safety of those materials.

How to proceed

It is very important to be aware of potential chemical safety issues regarding the reuse and recycling of materials containing known or unknown chemicals of concern. By being aware of this, many potential issues regarding the safety of the products can be dealt with and solutions incorporated into the recycling process before the product reaches the market.

When regulatory rules and guidelines are not yet suited for this fast-emerging field, a case-by-case risk-based approach to recycled materials is advisable which focuses on the applications. This type of screening is specifically relevant when the use of secondary raw materials could be for different applications with different exposure profiles than the original products.

I leave the final remark of this article to ECHA’s Executive Director Bjorn Hansen;

“Chemicals are fundamental to the circular economy – they are used in products and will either be recycled or discarded as waste. A circular economy cannot be discussed without looking into the legislation on chemicals and what is happening with hazardous substances in the entire chain of events. A smooth transition to a circular economy involves “finding the balance” between materials that have a value and need to be recycled, and the hazardous substances in them that should be eliminated.” (from: Chemicals are at the core of the circular economy and Europe’s future, ECHA newsletter September 2016, issue 3).


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