1 mei 2023

Circular Economy - opportunitiesand challenges for chemical policyregulationHelsinki, Chemicals Forum

Hans MeijerCoordinator Asbestos, Biocides and Chemical SubstancesMinistery of Infrastructure and the Environment, The Netherlands

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• Everyone is in favour of a circular economy

• So why is it be a problem to get there?

• “ The Devil is in the detail ”

• These “details” include issues related to the interface of the waste and the chemicals legislation

Introduction

1 mei 2023

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• Chemicals (REACH): safe use, quality related

• Waste: decrease waste generation and disposal, increase recycling and reuse, also quantity related

• Often these objectives coincide well, but sometimes they don’t…

• Missing: instrument how to decide on recycling or disposal in presence of hazardous substances

Legislation, objectives and instruments

1 mei 2023

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• At this moment, around 170 SVHC’s, an number that might be threefold in a couple of years

• Waste containing a certain SVHC can emerge in small quantities over the next centuries

• Identification of the presence of SVHC’s difficult (if not impossible)

• The alternative for recycling might not be that env friendly (landfill, incineration, long transport)

Extent of the problem

1 mei 2023

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• How to balance the advantages of recycling with the advantages of disposal?

• MSs and the EP all have their own way to decide.

• As such, whereas everybody shares the same objectives, different positions per substance!

• So how to find out if disposal or recycling is the best option for the environment?

Fight over individual substances

1 mei 2023

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• HBCDD: setting limit for POP-content: choice between 10 or 100 ppm, 100 ppm allowed for separation, reuse + recycling of bromine content In EPS: controlled reuse or disposal?

• DEHP: choice between landfill, incineration or recycling for restricted uses (low exposure)

• Rigid PVC waste containing Cd>0,1%, Pb>0,3%: recycling possible in waterpipes with three layers

Some examples

1 mei 2023

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• Challenging issue, no one size fits all solution

• Therefore urgent need for criteria interface w/c

• That should allow to on a case by case basis decide whether disposal or recycling is most environmentally sound

• Such methodology should include all relevant element along the life cycle like the options for future recycling and use of prime materials.

Conclusion

1 mei 2023

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Thank you for your attention!

Hans.meijer@minienm.nl

1 mei 2023