Chemical safety in the circular economy is ‘non-negotiable’

The European chemical industry supports the transition towards a circular economy as part of a strategy to make Europe more resource efficient. This can be achieved both by avoiding unnecessary material and energy losses throughout the life-cycle of products and maximising value by keeping resources circulating in loops, after the first usage, many more times than today.

Environmental reasons and business arguments suggest doing so. Over the past century, our industry has developed and scaled up to new projects and technologies which have significantly improved resource efficiency across the value chains of the most important sectors of our economies. Many further projects are currently under way. Their success will depend on whether they bring tangible benefits and are economically viable.

We look to the Parliament, the Council and the Commission to support an ongoing evolutionary process, working with the market to encourage innovation and investments in economically viable solutions, removing regulatory, administrative and financial barriers, and supporting the businesses investing in new promising areas.

The chemical industry has the know-how and the capabilities to make Europe more resource efficient over time. To tap the full potential of a circular economy, we ask policy-makers to take into account the following principles.

Life-cycle thinking. The solutions to be provided should be the most environmentally benign, cost-effective and socially acceptable over the entire life-cycle. If keeping materials in the loop were to consume more resources (eg. energy and water) than it saves, it would make no sense to pursue it.

Holistic value-chain approach. Creating partnerships across the whole value chain (including eg. chemical manufacturers, downstream users and consumers) is the right way forward.

Safety first. The circulation of resources in loops must be managed in a safe way for workers, consumers and the environment. The chemical industry can make a contribution to the circular economy in all its phases: product design, production processes, waste management, and from waste to resources.

Product design

As part of our commitment to sustainable chemistry, we develop substances enabling high-performance products which are durable, easily recyclable and easily repairable. There might be trade-offs in doing so: for example, recyclability could come at the expense of other performance characteristics. The overall balance of advantages in such cases can be accessed on the basis of a life-cycle approach that considers the benefits of use as well as the ease of recycling.

Promoting the consumption of products that involve high resource use or functionality losses in the use phase would be against the core principles of an innovative circular economy. A successful circular economy will be the outcome of a bottom-up process based on the development of fruitful partnerships all along the value-chain. Consumers will, ultimately, decide which products to purchase.

Production processes

The circular economy will benefit from a diversified raw materials base. Mineral, fossil-based, renewable and secondary raw materials all have a place in a competitive circular economy, as do alternative feedstocks (eg. CO2 from industrial flue gases) and should be accessible at a competitive price.

High value added and resource efficient uses of biomass should be promoted, while taking into account the diversity of the availability and quality of renewables across Europe. We support an approach based on life-cycle thinking: cost-effective and environmentally benign solutions will be adopted in the selection of alternative uses and types of biomasses.

To ensure the creation of a level playing field between different actors, subsidies and fiscal measures should not steer one use of biomass to the detriment of others. Nor should barriers (eg. customs duties and technical barriers) prevent European businesses from having fair access to renewables.

Therefore, we call on policy-makers to create a level playing field on the international market between European businesses and their global competitors with regard to access to renewables. Innovative production processes aimed at maximising efficient use of resources should also be encouraged.

For instance, the European Commission should consider support for integrated production processes where products and by-products are used as raw materials for the next production stage (industrial symbiosis). The European chemical industry has already embarked on this path, but excessive administrative burdens arising from both EU and national legislation are hampering further development.

Waste management

Moving from waste management to resource management should be the long-term objective of the circular economy. The first step would be to prevent valuable materials from being considered as waste altogether. All too often, materials which can be easily reintegrated in the production process, without any safety and pollution risks, are defined as waste.

By imposing unnecessary costs on businesses seeking to keep resources in the loop, such a wide interpretation of waste is in contradiction with the core principles of a circular economy. Therefore, we urge policymakers to clarify the concept of waste and that of by-products under the Waste Framework Directive. The latter should not hinder the further use of valuable materials.

Within the framework of the waste hierarchy, Cefic believes that an approach based on life-cycle thinking should be adopted to choose between different end-of-life management operations.2 For instance, energy recovery could be the best solution in cases where recycling activities entail excessive environmental impacts, economic costs or when recycling is not deemed safe. Landfilling could be justified as a last resort solution for residual waste for which no alternative has been found so far (eg. non-combustible industrial waste and asbestos waste).

From waste to resources

“Safety first” is and will continue to be our guiding principle. The recycling of chemicals of concern could be the solution when such substances can be managed in a safe and economically efficient way. The European chemical industry is fully committed to ensuring that the circular economy will abide by the same high standards embedded into the existing chemical and product legislation (eg. REACH and CLP). Thus, we will explore pragmatic solutions enabling recyclers to safely handle chemicals of concern in a cost-effective manner while protecting confidential business information (CBI).

To create a truly European integrated market, we support the elimination of the artificial administrative barriers preventing a free flow of secondary raw materials across Europe. Secondary raw materials should not, however, receive preferential treatment compared to other equally valuable raw materials.

Source: Cefic – the European Chemical Industry Council

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