CEFIC tagasiside tegevuskavale: "Kemikaalide, toodete ja jäätmete vaheliste seoste analüüs ning poliitikavõimaluste tuvastamine"

31.03.2017

CEFIC esitas Euroopa Komisjonile tagasiside tegevuskava kohta, mis käsitleb kemikaalide, toodete ning jäätmete vaheliste seoste analüüsi ning poliitikavõimaluste identifitseerimist. (Tegevuskava avaldati 27 jaanuar 2017).

CEFIC on teadvustanud, et Komisjon on tegevuskavas tuvastanud neli põhilist probleemi: esiteks ebapiisav informatsioon probleemsete ainete kohta toodetes ja jäätmetes; teiseks probleemsete ainete olemasolu taaskasutatud materjalides ja toodetes; kolmandaks ebakindlus, kuidas materjalid lakkavad olemast jäätmed ning neljandaks raskused EL jäätmete klassifitseerimise meetodite rakendamisel ja mõju taaskasutusele. CEFIC annab omapoolse tagasiside tuvastatud muredega tegelemiseks:  

Tutvu CEFIC seisukohtadega alljärgnevalt:

Cefic feedback to the Roadmap: "Analysis of the interface between chemicals, products and waste legislation and identification of policy options" – published on 27th of January 2017

The European chemical industry supports the transition towards a circular economy as part of a strategy to make Europe more resource efficient. This can be achieved by avoiding unnecessary loss of resources throughout the life-cycle of products and by keeping resources longer in use, after first usage, extending their life.

Such thinking driven by environmental and economic reasons already exists today in the chemical industry, which has a long, relevant experience in this field. The chemical industry can contribute to the circular economy in all its facets as evidenced by many examples1, e.g. through:
 product design, e.g. providing solutions to improve resource efficiency and longer life cycles of products;
 production processes, e.g. by setting up loops for processing and re-using chemicals in integrated production systems;
 turning waste to chemicals and resources;
 using alternative feedstock (e.g. CO2);
 ...

Cefic has taken note that the Commission identified four problem areas in the roadmap: "(#1) insufficient information about substances of concern in products and waste; (#2) presence of substances of concern in recycled materials and articles made thereof; (#3) uncertainties about how materials can cease to be waste; (#4) difficulties in applying EU waste classification methodologies and impacts on the recyclability of materials."

Cefic agrees that the above warrant further consideration, both in analysis and appropriate measures, and we are ready to play an active role. In addition, we would highlight that further emphasis is needed in investments and developing technology routes and methods (mechanical and chemical recycling, improved sorting techniques, analytical methods, ....) along the recycling chain to improve the uptake of secondary raw materials. Substances in consumer products can sometimes be difficult to track; value chain collaborations will be critical to develop and implement solutions. Any solution should:
 recognise that individual product waste streams are very different, necessitating different solutions and thus a differentiated approach for each value chain;
 prioritise waste streams for solution development; taking into account previous Commission studies;
 complement and not undermine existing legislation;
 address how to effectively move from waste to resource efficiency;
 recognise the high resource efficiency potential of chemical products during the use phase;
 recognise the vital role of specific substances to achieve desired products properties; the presence of these substances does not necessarily prevents their re-use;
 encourage recovery into fuels and energy for products and articles that cannot be recycled in a safe and sustainable way.

Cefic, together with its members, have analysed the above mentioned four problem areas, and suggest some preliminary ideas to solve them. We are most willing to have further conversations with the Commission and other interested stakeholders to bring these ideas forward.

Issue #1: "Insufficient information about substances of concern in products and waste"
In the context of a Circular Economy, and in particular for post-consumer waste streams, Cefic is aware that further consideration needs to be given to the information needs of recyclers to enable safe recycling, complying with all legal obligations. REACH, CLP and/or other sector regulations in place, have already mechanisms to communicate and manage the presence of SVHCs. In cases where there are knowledge gaps at the recycling stage, due to e.g. loss of information at the use and waste stage, (relevant in particular for post-consumer waste and uncontrolled imports) or, uncontrolled contamination during use, collection and sorting phases, Cefic is of the opinion that these can be best overcome in a joint effort of all partners in the industrial – including the end-of-life treatment – value chains in an optimal collaborative approach. A thoughtful assessment of the input materials and their further treatment by the recyclers, would be essential for having the complete picture to comply with REACH, CLP and/or sector regulations.

The chemical industry is ready to be an active contributor to such value and recycling collaborative approaches and to support these with its knowledge and expertise on substances and their safe use, with due consideration for protecting confidential business information (CBI). These collaborative approaches could also benefit from chemical companies' ongoing transparency efforts (e.g. GPS product safety summaries), and other relevant sector and cross-sector initiatives such as the ICCA Value Chain Outreach, and the UNEP Chemicals in Product Program. Of potential interest are the voluntary collaborations between ECHA and Industrial Associations, aiming at screening out those substances to further investigate from a safety perspective.

Issue #2: "Presence of substances of concern in recycled materials and in articles made thereof"
"Safety first" is and will continue to be our guiding principle. In Europe, REACH and CLP are the pillars of chemical legislation ensuring the European society a high level of protection. The manufacturing of products made from secondary raw materials should meet an equivalent level of protection embedded into the existing chemical (REACH and CLP) and sector legislation to fully protect humans and the environment.

In the opinion of Cefic, REACH and CLP legislation are appropriate and should remain the "guardianlegislation" at the entrance of any new material cycle. Coordination between the different pieces of legislation – REACH, waste and, if applicable, specific product legislation is essential. In this respect, we consider e.g. the guidance given by the German UBA on "REACH and the recycling of plastics – Reference manual for an appropriate implementation of the REACH requirements of the operators of recycling plants" a good example to look further into, as it ensures compliance through quality and safety management.

The Commission brought an additional consideration in its Roadmap: "[...], no agreed methodology [exists] to determine the overall costs and benefits for society of the use of recycled materials containing such substances compared to disposal of, or energy recovery from, the waste and the impacts of production of virgin materials in case recycling is prevented." Given that REACH and CLP are and should remain the "guardian-legislation" in a circular economy, Cefic suggests to look into the need to further develop supporting guidance derived from REACH guidance, for informed decision taking in case of recycling, with due consideration to the presence of SVHCs. Concretely, the outcome could be guiding principles or a decision tree, clarifying under which conditions materials can be recycled. All concerned stakeholders should be involved in this process. Cefic is willing to bring its expertise and knowledge to the table, as we believe such guidance would benefit from the same multi-stakeholder approach as in issue #1 – insufficient information.

Issue #3: "Uncertainties about how materials can cease to be waste"
The practicalities of managing post-consumer articles and industrial process waste are significantly different. It may therefore be appropriate to consider these waste types separately when considering options. In the long run, Cefic argues that to ensure a smooth transition towards a Circular Economy, the EU should move from a waste to a resource oriented thinking. This will thus require removing uncertainties related to the end-of-waste statute which can be associated to a non-harmonised interpretation at Member State level, but also that by-products concepts and the definition of waste needs to be improved. Cefic is willing to discuss this issue further and illustrate it with examples.

Issue #4: "Difficulties in applying EU waste classification methodologies and impact on the recyclability of materials"
Cefic will re-examine this issue when more information becomes available.

Viimati uuendatud 12.04.2017