In recent years, many companies have set ambitious targets to increase the recycled content in their products and packaging. However, they often realise that secondary material, which is safe to use in their intended application, is very rare.
Plastics coming from all kinds of value chains, including those that use substances that are classes as (very high) concern are often all mixed together at their end-of-life and there is no information available on their chemical content. Due to the lack of traceability of chemicals in products and packaging, secondary materials don’t then meet product-specific requirements to (re-)enter the market.
Chemicals action in the electronics industry
A sector that is ahead of the curve in terms of tracking chemicals is the electronics industry. The EU Restriction of Hazardous Substances (RoHS 2) Directive supports the goals of the Waste Electrical and Electronic Equipment (WEEE) Directive by banning hazardous substances from entering waste streams, thus eliminating barriers to recycling and being made into new products.
The RoHS 2 Directive requires producers of electrical and electronic equipment (EEE) from 2011 to find out whether there are specific substances in their products and parts. This is a huge advantage both in meeting new regulatory requirements such as the Substances of Concern In articles as such or in complex objects (Products) (SCIP) notifications established under the Waste Framework Directive, and in making faster progress on sustainability and circularity.
In addition, the electronics sector has developed business processes, standards, and tools, mapped out and crucially built good relationships along their entire value chain to comply with these requirements. Other sectors that acted later faced an almost impossible challenge to investigate the content of substances of very high concern above 0.1% along the entire supply chain in all the articles they produce.
Challenges of chemicals action
However, just knowing what chemicals are in your product is obviously not enough. It tells you what you may start trying to eliminate, but those chemicals are (mostly) there for a reason, providing a specific technical function.
Safer alternatives might not be available yet and industries should strive to avoid regrettable substitution (such as substituting bisphenol A with bisphenol F). Even the RoHS Directive acknowledges that replacement of a specific chemical in a specific application might not be possible and allows for exemptions.
Opportunities for the electronics industry
The chemicals used in EEE will undeniably rule out some recycled materials markets with particularly stringent standards for secondary materials such as toys, and more progressive brands such as IKEA who don’t allow recycled plastics from the electronics industry in their products. But with good knowledge of the chemical content of its products, and the ability to leverage good relationships with supply chain partners, the electronics industry is well placed to drive reuse, recycling and even ‘closed loop’ use of materials.
The electronics industry appears to be ahead of the game on chemicals mapping. Other industry sectors will need to catch up with all the changes brewing in the European regulatory arena or risk being blamed for polluting potentially valuable recycled material streams. The EU, to meet their goals under the Green Deal and toxic-free environment initiatives, has decided to implement more significant changes to the chemical’s legislative framework.
When Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) was implemented to address this, many thought implementing some of the building blocks would be impossible, such as registering the majority of existing chemicals by industry. And yet, twenty years later, several countries around the world are implementing REACH-like legislation, and the EU is aiming to go even further and faster in addressing chemicals risk. Legislation such as Classification, Labelling and Packaging (CLP) Regulation, REACH, RoHS, the Ecodesign Directive (that will cover all products instead of just the energy related ones) and others are under review and industry will need to follow these changes closely to be able to comply with the new requirements and thrive in this new era as we strive toward a toxic-free Europe.
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How can Anthesis support chemicals action?
If you need any help understanding where your organisation stands and what your next steps could be, please don’t hesitate to reach out. Anthesis has the subject matter expertise to drive resolutions as well as a holistic approach to supplier engagement and data collection that will provide more flexibility and responsiveness to many of these new requirements as well as future obligations and initiatives.