This document discusses chemical problems that can disrupt a circular economy approach. Specifically, it notes that hazardous chemicals contained in long-lasting products can contaminate recycled materials if those chemicals have since been banned. It provides examples of bisphenol A contaminating recycled paper and brominated flame retardants being found in black kitchen plastics and furniture. The document recommends designing non-toxic, safer products and ensuring recycled materials are properly regulated to address these issues.

1. Circular economy & chemicals:
Problems and Solutions
Dr A. Michael Warhurst
Executive Director, CHEM Trust
OECD Ministerial meeting
29th September 2016
www.chemtrust.org.uk
@chemtrust @mwarhurst

2. Chemical problems for CE
• A circular economy should lead to more reuse, recycling,
remanufacture – and longer product lifetimes
• But hazardous chemicals can disrupt this:
– Long lasting products may contain chemicals that have since been
banned, disrupting recycling & remanufacturing
• (& in theory re-use, though this is often ignored)
– Contamination of feedstock; it’s harder to control feedstock quality
for a recycled material vs a virgin one
• Two examples:
– Bisphenol A (BPA): High volume chemical, used in food can
linings, thermal paper, polycarbonate plastics
– Brominated flame retardants (BFRs): Large group of chemicals,
used in furniture, electronics, building products.

3. 1) Bisphenol A (BPA) in thermal paper
• BPA is used in thermal paper (e.g. till
receipts)
– This then enters the recycled paper stream
• Problem for circular economy:
– Recycled paper & card (e.g. pizza boxes)
contaminated with BPA [1]
– BPA an endocrine disrupting chemical, banned in
baby bottles
• Solutions:
– Stop recycling thermal paper with other paper?
• Impractical?
– Restrict BPA use in thermal paper?
• EU is doing this [2]
– Regulate recycled paper use in food contact [3]?

4. 2) Brominated Flame Retardants in kitchen plastics
• Brominated flame
retardants (BFRs) used in
plastics, e.g. in electronics
– many restricted, some UNEP
POPs (e.g. HBCDD &
PentaBDE [4])
• Researchers found in
black kitchen plastics on
sale on EU market
– Presumably through recycling
of e.g. electronics waste [5]

5. 3) BFRs in furniture & building products
• Widely used, long lived products
– Increases the chance that will contain banned
chemicals by the time they enter the waste stream.
– A reservoir of hazardous chemicals [6]
• Recycling can spread contamination
– E.g. BFR-contaminated polyurethane is being
recycled into carpet backing in USA [7]
• Solutions
– Rapid action to remove problem chemicals from
products, at design stage (including pre-regulation)
– Not everything can be recycled/remanufactured –
contaminated materials may need to be disposed
of; but information flow needed
– Balance value of resource vs concern re hazard in
policy & regulation

6. Recommendations
1. Design non-toxic products, with faster, more
precautionary, safety assessment and
regulation of chemicals
2. Ensure recycled materials & remanufactured
goods are properly regulated (with
enforcement), e.g. paper/card food contact
materials, carpet backing etc.
3. Improve (global) information flow on
hazardous materials in finished products
4. Some materials should not be recycled
See briefing:
http://www.chemtrust.org.uk/circulareconomy

7. References
[1] Test: Unwanted chemicals found in pizza boxes, Danish Consumer Council, 19th Oct 2015
http://kemi.taenk.dk/bliv-groennere/test-unwanted-chemicals-found-pizza-boxes
[2] EU Chemical Agency committee agrees that Bisphenol A in receipts poses risk to workers, Jun
2015:
http://www.chemtrust.org.uk/eu-chemical-agency-committee-agrees-that-bisphenol-a-in-receipts-
poses-risk-to-workers/
[2] Chemicals in food contact materials: A gap in the internal market, a failure in public protection,
CHEM Trust, January 2016:
http://www.chemtrust.org.uk/foodcontact/
[4] Listing of POPs in the Stockholm Convention, Stockholm Convention:
http://chm.pops.int/TheConvention/ThePOPs/ListingofPOPs
[5] Occurrence of brominated flame retardants in black thermo cups and selected kitchen utensils
purchased on the European market, Food Additives & Contaminants: Part A, Volume 30, Issue 11,
2013:
http://www.tandfonline.com/doi/abs/10.1080/19440049.2013.829246#.VYp4uVWWGMU
[6] Stubbings, W. A., & Harrad, S. (2014). Extent and mechanisms of brominated flame retardant
emissions from waste soft furnishings and fabrics: A critical review. Environment International, 71,
164-175
http://www.sciencedirect.com/science/article/pii/S0160412014001822
[7] Optimizing Recycling: Post-Consumer Flexible Polyurethane Foam Scrap Used In Building
Products, Health Building Network, July 2016:
http://www.healthybuilding.net/news/2016/07/29/post-consumer-flexible-polyurethane-foam-scrap-
used-in-building-products