Responses to the European Commission consultation on the chemicals – product – waste interface show the challenges posed by legacy chemicals in plastics and textiles.
Whereas the EU waste management industry FEAD argues that recycled products should in some cases be allowed to contain traces of SVHC (Substances of Very High Concern) legacy compounds, environmental NGOs (such as ChemTrust and ECOS) want these chemicals excluded from recycled materials. Both agree that legislation should prevent problematic chemicals being added to virgin materials. There is also disagreement as to whether EU End-of-Waste criteria are an appropriate tool to address this question.
“Stakeholder consultation paper chemical, product, waste interface”, European Commission http://ceoe-tenerife.com/wp-content/uploads/2017/05/2017-04-12-Instructions-stakeholder-consultation-Chemicals-products-wa….pdf