≡ Menu

The Circular economy: To get it right we must address hazardous chemicals

A Circular Economy is an important component of a future-focussed, sustainable, economy, and CHEM Trust therefore welcomes the European Commission’s current consultation on the Circular Economy.

We have submitted a briefing to the consultation making recommendations for policies that are needed in order to ensure that the circular economy doesn’t end up perpetuating the use of hazardous chemicals. The aim of Europe’s policies on the circular economy has to be the creation of a clean circular economy, as this is the only truly sustainable approach.

Our key recommendations:

1) A move to non-toxic products, thus removing problems in recycling

  • Regulations, regulators and industry must ensure that all chemicals of very high concern are phased out of products as soon as possible.Policy brefing circular economy

2) Faster, more precautionary, safety assessment of chemicals, assuming a circular economy. Industry should move away from problem chemicals. Faster identification of chemicals of very high concern, with rapid action to ensure they are substituted with safer alternatives.

  • Safety assessments should assume that a circular economy is going to be in place, e.g. that 100% of sewage sludge will be used as fertiliser.
  • Companies should take a forward-looking approach when producing products, avoiding chemicals likely to be restricted in the future, e.g. the ChemSec SIN list.

3) Better information flow on hazardous materials in products, and controls on chemicals in imported products

  • The supply chain, including consumers and recyclers, should have easy access to information on identity and properties of hazardous chemicals in products.
  • Imports should be subject to the same restrictions and information requirements.

4) Some materials should not be recycled

  • Assessments should balance the value of the resource and the hazard of the chemical, with a default of no recirculation of hazardous substances.
  • The EU is currently pushing to permit the recycling of products containing dangerous persistent organic pollutants. This promotion of persistent pollution is short sighted, endangering high quality recycling, health and environment.
    • Update, 7th Sep 2015: CHEM Trust has joined with other NGOs to write to Commissioner Vella calling for the EU to stop calling for the recycling of materials containing the brominated flame retardant DecaBDE.


The circular economy will only be successful in the long term if customers – including the public – are confident in the quality of recycled material. If this confidence is removed, then the market will demand virgin materials, and the attempt to create a circular economy will fail.