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Circular Economy Chemical Policy Regulation Challenges
1. 27 mei 2016
Circular Economy -
opportunities
and challenges for
chemical policy
regulation
Helsinki, Chemicals Forum
Hans Meijer
Coordinator Asbestos, Biocides
and Chemical Substances
Ministery of Infrastructure and the
Environment, The Netherlands
2. 2
• 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
27 mei 2016
3. 3
• 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
27 mei 2016
4. 4
• 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
27 mei 2016
5. 5
• 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
27 mei 2016
6. 6
• 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
27 mei 2016
7. 7
• 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
27 mei 2016
8. 8
Thank you for your attention!
Hans.meijer@minienm.nl
27 mei 2016