Contaminants and substances of concern in the waste management sector

FEAD, representing the European Waste Management Industry, is committed to advancing sustainable waste management practices across Europe. A critical aspect of this mission involves addressing contaminants and substances of concern in waste streams to ensure the safety and quality of recyclates, protect human health, and minimize environmental impacts. The European objective should be to find the right balance between achieving zero pollution while advancing in circularity.

FEAD emphasizes the need for a balanced and pragmatic approach that considers the complexity of waste management processes and the challenges associated with the measurement, recycling, elimination, emission, and contamination control. FEAD strongly supports the phasing out of substances of concern at the production stage to limit their presence in the material cycle. In addition, to ensure the safe substitution of substances of concern, the environmental impact and the end-of-life of the substitute must be thoroughly assessed. This proactive approach will help “close the tap” on contaminants. The cooperation of the manufacturing sector is also needed to increase transparency on the composition and required treatment of their products. These restrictions must be matched by equivalent standards and strict enforcement on imports of products containing these substances.

When it comes to products’ end-of-life, we outline the following recommendations for effectively managing contaminants in the waste sector.

• FEAD aims for maintaining the same standards for recyclates as for primary materials for their intended final applications. It is essential that recycled materials meet comparable safety and performance criteria to ensure market acceptance and consumer trust. In the long term, higher thresholds for contaminants in recyclates should not be imposed, as this could undermine the credibility and utilization of recycled materials. Our goal is to produce recyclates that are safe, reliable, and competitive with virgin materials, with a phased approach that allows time for investment in measurement, separation and treatment techniques.
• FEAD promotes transparency for ensuring the safety and quality of recyclates. FEAD advocates for the development and implementation of standardized measurement methods to accurately assess contaminant levels in waste streams. Establishing uniform standards will enhance transparency, facilitate regulatory compliance, and promote trust among stakeholders, including consumers, policymakers, and industry players.
• Decontaminating waste to remove harmful substances is a priority for FEAD. Investing in advanced technologies and processes for the decontamination of waste materials will enhance the quality of recyclates, making them safer for various applications. FEAD encourages the adoption of innovative decontamination methods that are efficient, cost-effective, and environmentally friendly.
• FEAD recognizes the need for a phased approach to implementing new standards and technologies for contaminant management. While the aim is to achieve the same quality standards for recyclates as for primary materials, time for investment and development is needed. Nevertheless, the transition period should not be unnecessarily prolonged. Adequate, but not excessive, timeframes will allow for the development and deployment of effective measurement methods, separation techniques, and decontamination technologies. Only in cases where absolutely necessary should extended transition periods be considered.
• For waste streams that cannot be effectively decontaminated but still hold recycling value, FEAD supports a risk-based approach in terms of uses on a case-by-case basis. This involves identifying specific applications where the use of such materials poses no risk to the environment or human health. Implementing closed-loop systems if possible, and ensuring traceability is crucial to managing these waste streams safely. By adopting a risk-based approach, we can continue to recycle valuable materials while safeguarding public health and the environment. Such approach should also help dealing with the legacy substances
• FEAD proposes funding mechanisms based on the polluter pays principle to ensure producers contribute to the treatment costs of substances of concern. While an EPR scheme may not be suitable here, FEAD supports alternative methods to ensure fair distribution of financial responsibilities so those introducing harmful substances bear the costs of their safe management and disposal.

FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 19 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fueling €5 billion of investments into the economy every year.