The interface between chemicals, products and waste legislation (communication)

EESC opinion: The interface between chemicals, products and waste legislation (communication)

Key points:

  • The Committee welcomes the approach taken by the Commission in exploring systematically the relevant range of options which could help resolve a series of problems identified at the interface between chemical, product and waste legislation.
  • The pro-active, long-term view of the type being adopted by the Commission on this matter is commended. The transition process will, inevitably, be of extended duration, but will require constant encouragement to be driven forward and need to take account of ongoing developments in identification and processing technology.
  • The occupational health and safety of workers in recycling plants are also at risk without comprehensive action, particularly on dealing with the issue of legacy substances. The provision of comprehensive information to trade unions is therefore essential.
  • The full application of the REACH Regulation and other legislation on chemicals already in place should be prioritised. Existing legislation which prevents hazardous chemicals from initial entry to the material cycle is still not being fully used, especially concerning entry into the EU on products from third countries.
  • The Committee identifies and advocates further investment in adapted sorting equipment by recycling companies and the consideration of economic and technical support measures in this area.
  • The Committee strongly supports the view that better information on the presence, location, and concentration of hazardous chemicals in products and materials recovered from waste can reduce problems encountered by operators in the recovery chain.



The Circular Economy Action Plan contained the following two-fold objectives to be achieved:

  • enabling recycling and improving the uptake of secondary raw materials; and
  • substituting substances of concern and, where this is not possible, reducing their presence and improving their tracking.

These two objectives, one stemming from waste policy and the other from chemicals policy, have often been perceived to be in opposition to each other.

The aim of this Communication is to promote a broad discussion in the Union on how the major elements identified at the interface between chemicals, product and waste legislation can be addressed.