CHEM Trust in circular economy chemicals warning

Proposals to permit the recycling of products containing potentially hazardous material would be ‘short sighted’, a chemical protection charity has suggested in response to the EU Commission’s circular economy consultation.

The Council will seek to build a greater understanding of the resource and energy needs of industries of the future

CHEM Trust, a UK registered charity that works to prevent man-made chemicals from causing long term damage to wildlife or humans, has urged the Commission to weigh up the benefits of encouraging the recycling of a material, over any potential harm to the environment.

CHEM Trust has called on the EU to ban recycling products that contain harmful chemicals
CHEM Trust has called on the EU not to recycle products that contain harmful chemicals

Materials that have come under scrutiny in the charity’s response include black plastics, which are used in kitchen goods and could be contaminated ‘with brominated flame retardents’, plastic toys, furniture and construction materials.

The organisation argued that it is wrong to assume recycling is always the best option when waste contains hazardous chemicals, and that some landfill is still the safest place to dispose of some materials, such as PVC.

Its response calls on the EU to end its support of recycling products that contain ‘dangerous persistent organic pollutants’, which it suggests endangers high quality recycling and creates exposure to harmful chemicals.

Food packaging

Significantly, the charity has recommended investigating food contact materials, such as packaging, which can include ‘phthalates, Bisphenol A (BPA), and perfluorocarbon coatings’.

On reducing the risk of chemical contamination, the position paper states: “In general, the best way to produce good quality secondary raw materials is to collect materials separately. This also makes it much easier to establish whether there are any chemical hazards.

“Some waste management techniques process mixed waste and then create materials that are complex mixtures – such as slags and ashes. It is often hard to establish the chemical safety of such mixtures, so it will be hard to satisfy REACH requirements if they are to be accepted as a product.”


CHEM Trust also raises the problem of recycling materials that are likely to be banned in the coming years. It highlights the use of BPA in thermal paper and suggests there would be ‘little resource benefit’ coming from recycling the small amount of paper involved.

Better information flow on hazardous materials in products, as well as controls on chemicals in imported products, are also areas the organisation believes could be improved within the supply chain.

CHEM Trust concludes: “The circular economy will only be successful in the long term if customers – including the public – are confident in the quality of recycled material. If this confidence is removed, then the market will demand virgin materials, and the attempt to create a circular economy will fail.”

The way hazardous chemical waste is assessed and classified is changing. In June, the European Classification, Labelling and Packaging Regulation came into force in the UK requiring many hazardous waste chemicals to be assessed against new criteria.


The new system is based on hazard classes, categories and statement codes rather than previous risk phrases and categories of danger, meaning previously non-hazardous materials could now be classified as hazardous (see story).

The EU Commission is to assess the responses to its circular economy consultation, which closed on August 20, before laying out the policy options later in the autumn.


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