Chemicals are an important part of our everyday lives. They ensure that we have heat, electricity, goods, clothing and access to telecommunications, social-media, and music wherever we are. Chemicals are also a significant contributor to our economies. Many things we observe in the natural world around us are caused by chemical reactions.

But chemicals have also a hazardous and risky side and we should minimise any harmful impact from exposure to them. Proper and sound management/disposal of waste containing chemicals is mandatory and needed to protect people and the environment.

In this context the European Commission within the Green Deal is developing the Chemical Strategy and the Zero Pollution Strategy and various other actions to improve  the protection of people and the environment against hazardous chemicals and at encouraging innovation for the development of safer alternatives.

From a waste management perspective, in order to improve the circular economy which requires more and more ambitious targets in terms of quantity and quality, we would like to stress the following needs related to Chemicals and waste:

FEAD Key messages:

• More information

When treating waste, the operators may face a lack of information about the composition of the waste received. This is particularly critical for hazardous waste. Such information is essential for several reasons: compliance with the acceptance criteria in the facilities and, where applicable, the compliance with legislative requirements such as POP Regulation or Seveso requirements on site, verification of the chemical compatibility to prevent any risk of accident and protection of employees in terms of health and safety.

• Need for guidance

Together with the need for more information we call for the creation of a realistic set of guidelines on what could be found in different waste streams and how to treat them in a safe and environmentally responsible way

• Decrease of the use of Substances of Very High Concern

This topic is fundamental and in order to improve the quality of recyclates as well as the safety of the workers and the environment we should, as much as possible, get rid of substances of very high concern in the products. If substitutes are unavoidable we then claim for more information on products and on how to remove and treat those substances in a safe and environmentally sound manner.

• Mandatory eco-design

We call for a true dismantlability and recyclability of products through mandatory standards for designing products, reducing or phasing out substances of very high concern. A robust eco-design policy will be also a key tool for the prevention of the generation of waste.

• Enforcement and implementation of EU legislation

While ambitious targets push for more recycling in terms of quantity, a qualitative approach is also needed, as recyclers are investing in downstream parts of the value chain. This investment will only be made possible by the proper implementation and enforcement of the existing international and European legislation (REACH, RoHS, POPs) at all stages and by all actors, with a specific attention to imported goods.

• Legacy substances

Because legacy substances are a barrier to recycling we call for a specific decision-making methodology to support decisions on the recyclability of waste containing substances of concern.

In order to improve the protection of human health and the environment from the risks that can be posed by chemicals, the Commission needs to strike the right balance between recycling/recovery policy as proposed by the new Circular Economy Action Plan and the aims of chemicals/products legislation.

For further information, please contact: info@fead.be