Stakeholder Consultation on Chemical, Product, Waste Interface

Brussels, July 2017

There is no doubt that moving away from a linear production model towards achieving a truly Circular Economy in Europe is an absolute priority. This translates notably into increased recycling rates for all materials. Nevertheless, re-entering waste materials into the production process increases the risk of contamination of the final products placed on the market. Likewise, increased recycling rates as proposed in the revised waste legislation of the Circular Economy Package will have the natural effect of putting more pressure on the sorting, treatment and transformation of waste into quality secondary raw materials that can replace virgin raw materials in a production process.

And yet, managing this transition will be the guarantee of success of a circular economy. The European Container Glass Industry is ready to play its role in this important challenge for the future, as it has been doing so since the 1970s when post-consumer glass recycling started with the establishment of the first separate collection systems in Europe.

The European Commission is right in addressing the issue of the interface between chemicals, products and waste as the success of the circular economy will depend on a market for secondary raw materials that competes in terms of cost, quality and safety with virgin raw materials. However, the circular economy should not come at the expense of human health and should also protect the environment from the risks caused by migration and release of hazardous chemicals in material cycles.

All consumer and environmental risks linked to hazardous substances and chemicals of very high concern must be properly identified and addressed to foster trust from businesses and consumers in the market for secondary raw materials, which is the basis for a well-functioning circular economy.. See the consultation reply from FEVE here.