“The path to safer and cleaner material cycles is promoting substitution”

Interview with Kęstutis Sadauskas, Director for Circular Economy & Green Growth at the European Commission’s DG Environment, about the EU’s upcoming “Chemicals Strategy for Sustainability”

For the first time in 20 years the European Commission will present a comprehensive review of its entire chemicals policy this autumn, in the form of its Chemicals Strategy for Sustainability. As part of the European Green Deal this has high priority.

Chemicals are all around us. They are essential for all products, from food to medical treatments, from buildings to consumer electronics. The chemicals industry is the fourth largest in the EU, with 28,000 companies employing 1.2 million people and generating around 170 billion per year of added value for the European economy.

At the same time pollution from chemicals has major environmental and health costs, with increasing evidence of contamination of land and rivers, but also of blood and body tissue. The new strategy will be expected to deliver on the announced ambition of the “Zero Pollution Action Plan”(to be released in 2021), to deliver a toxic-free environment to better protect citizens and the environment against hazardous chemicals.

It will also have to address critical issues in delivering the vision of the Circular Economy Action Plan, with legacy chemicals posing real problems for recyclers. The longer-term aspiration is to strengthen and simplify the legal framework and achieve full coherence between the laws implementing waste, products, and chemicals policies.

With such high stakes, growing attention is being directed on the intentions of Kęstutis Sadauskas, the Director charged with leading the development of the Commission’s proposals for the new chemicals strategy.

Mr Sadauskas, while chemicals are all around us, their crucial role in the circular economy has often been overlooked. Specifically, the elimination of hazardous chemicals in materials for reuse and recycling is a prerequisite for a circular economy to function. How will the European Chemicals Strategy for Sustainability enable the visions of the Green Deal and the Circular Economy Action Plan?

The European Green Deal is the growth strategy for Europe. It clearly states the ambition to transition towards a zero pollution and toxic-free environment, as well as to develop a circular economy where resources are kept in use for as long as possible. Therefore, a circular economy and the new Chemicals Strategy are closely interlinked.

What are the primary challenges to establishing an overarching regulatory framework required to streamline the existing EU legislation on chemicals, waste, and products?

The Commission has identified four main issues to be addressed in order to ensure a coherent relationship between chemicals, product and waste legislation: The first issue is the presence of banned or restricted substances in waste streams, so called “legacy chemicals”. Secondly, waste operators lack information on the presence of substances of concern in products. Thirdly, EU rules on end-of-waste are not fully harmonized. And neither are rules to decide which wastes and chemicals are hazardous.

In the Circular Economy Action Plan (CEAP), the Commission has already committed to implement certain actions to improve this interaction, for example with regard to the progressive tracking and minimisation of substances of concern in product supply chains and ultimately in waste and recycled materials. However, more information on some of these issues is needed in order to define effective solutions and future courses of action.

To that end the Commission is also preparing, or has already published, a number of studies. In particular, the “Clean material recycling project” (CleaR) study from April 2019 provides a good basis for discussion regarding the presence of legacy substances in waste and recycled products. A new study monitoring end-of-waste criteria at national level and collecting best practices as well as a feasibility study on the flow of information from the supply chain to waste operators will be published soon.

If there are trade-offs between zero pollution and circularity, what will take priority: (1) the substitution of hazardous legacy substances, or (2) high quality recycling and pure secondary materials?

It seems clear that the path to safer and cleaner material cycles is promoting substitution of substances of concern and avoiding their introduction in new products, whenever possible. The first CEAP already mentioned such a transition towards non-toxic material cycles. The 2nd CEAP has put forward initiatives that will contribute to this, particularly through upstream actions, for example in the context of the future legislative initiative on sustainable products.

In the short and medium term, and particularly to address the case of legacy substances that are already present in waste streams, this transition has to be managed. An assessment needs to be carried-out to ensure that future policy initiatives result in the best overall outcome for society.

The Chemicals Strategy will contribute to setting up the framework for action on this field. However, the scope and details of these and other new initiatives that will contribute to the attainment of safer and cleaner material cycles are still being discussed.

Do you think these trade-offs can be overcome by technology and digitalisation?

Technology certainly has an important role to play. Via its research and innovation framework programmes, the Commission is supporting new technologies that can contribute to the objective of promoting the uptake of clean, safe, and high-quality secondary raw materials. This is achieved by supporting the development of technologies that promote the upstream substitution of chemicals and by those that enable better downstream sorting and decontamination of waste.

In addition to these, improved digital solutions for tracking and managing information on substances of concern in supply chains are also have an essential role to play in achieving these objectives.

Talking about decontamination, do you think chemical recycling technologies could be a viable solution to eliminate legacy substances from the waste stream and thus facilitate circularity?

Chemical recycling is a promising technology. However, some challenges remain, including the need for more information on the overall environmental performance of these technologies, in particular regarding energy consumption and nature and safety of the process output. A life-cycle approach needs to be followed in order to consider all the possible benefits and risks of this new approach, including on climate.

Finally, the results of ongoing pilot projects still need to be expanded to have a representative picture of the possibilities of this technology.

The COVID-19 crisis increases the urgency to step up action to ensure stronger protection of citizens’ health, support the socioeconomic recovery of Europe while pursuing the green and circular transition. What are the instruments and incentives the EU will provide to help companies adopt the principles of circularity for chemicals in a cost-efficient manner, by replacing hazardous substances or re-designing products for example?

The Chemicals Strategy for Sustainability has among its main goals: First, to protect citizens and the environment better against hazardous chemicals and second, to encourage innovation for the development of safer, more performant and sustainable alternative chemicals and technologies, thus improving competitiveness.

In the context of the current crisis the Commission is very well aware of the importance to support recovery and the need to continue promoting research and development for the sustainable transformation of the chemical industry and the creation of green and sustainable manufacturing capacity in Europe. The details how this will be addressed in the strategy are currently still being discussed.

To increase environmental and health protection, the Strategy will explore how the regulatory framework can rapidly reflect scientific evidence on the risk posed by, inter alia, endocrine disruptors, hazardous chemicals in products including imported ones, combination effects of different chemicals and very persistent chemicals like PFAS. The Strategy is also linked to other priorities of the European Commission, including the digital transition, Europe’s beating cancer plan and the Industrial Strategy, to mention just a few.

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