ChemSec has published a report that addresses the issue of the low level of recycling of plastics and textiles. The report describes well the many barriers to recycling. ChemSec believes that there is a clear need to design out toxic chemicals upstream, eliminating the need for chemicals to enter the material system in the first place, or substituting safer alternatives where possible. The report states that designing out hazardous chemicals from upstream materials should be addressed as the first priority.

https://chemsec.org/publication/chemicals-business,circular-economy/what-goes-around/

Some important extracts from the Executive Summary

• A number of roadblocks still need to be removed for the circular economy to gain momentum…..one important roadblock [is] the issue of chemicals of concern in current material flows.…we look at what is known about [them] in recycled materials.

• Companies struggle to increase their use of recycled materials in products while staying compliant with chemical requirements, both legal and their own.

• It is obvious that the most efficient solution to stop circulating hazardous chemicals is to dramatically speed up the phaseout of chemicals of concern from the production of new materials. Recyclability, including chemical content, must be considered right from the design stage.

• New recycling technologies and tracking methods will play an important role, but their contribution is limited, which means that the circular economy cannot expand as long as new materials contain chemicals of concern.

The report gives published examples of how plastics additives are present in recycled materials. These are well-referenced. For textiles there are no quantitative examples in the report about hazardous substances. 

The report examines how tracking of chemical content is needed. With some exceptions, such as deposit-refund systems for PET bottles, different plastic materials become mixed during collection and therefore need to be sorted into homogenous waste streams. This is done either manually or with automated sorting based on some physical property, such as density, infrared absorption, or a combination of several properties. As a broad generalisation, intentional additives cannot be screened for, and information about their presence is lost unless some other analysis is performed. 

Several optical marking methods are described.

In the view of ChemSec, much of the regulation that is relevant for recycled material is either outdated, in the making, or open to exceptions that could compromise the content. If the use of recycled material is to increase, there needs to be a shift in the regulatory baseline, applying both the precautionary principle and recognising the need for toxic-free material cycles in all regulatory measures.

Financial opportunities are described, on the (unproven) assumption that removal of hazardous substances from plastics would increase the amount of recycling.

GCD considers that ECHA’s SCIP database could have an impact, as may the essential use concept currently under discussion. These are not discussed in the report.

Overall, ChemSec should be congratulated for having put together an experienced team of staff and consultants who have highlighted some serious concerns.