NGO position paper on the interface between chemicals, products and waste

In reaction to the Commission “Communication on the implementation of the circular economy package: options to address the interface between chemical, product and waste legislation1 ” (“The Communication”), the undersigning organisations intend to provide feedback on the discussions initiated by the Commission and propose further measures in order to achieve a clean circular economy.

The legislative framework of chemicals, products and waste are currently dissociated. But to achieve a clean and safe circular economy and contribute to a non-toxic environment as referred to in the 7th EAP and to the 2030 Agenda for Sustainable Development Goals (SDGs)2 , it is necessary to build bridges between the different instruments of the chemicals, products and waste legislations.

In line with the Circular economy strategy objectives, the undersigning organisations aim to achieve both goals of resource efficiency and detoxification of materials. The Commission’s initiative is a key opportunity to settle a framework that mutually reinforces the objectives of the chemicals, products and waste policies.

We welcome the Commission’s initiative and support the development of further actions to address the four challenges identified in the Commission’s Communication to approach the interface between chemicals, products and waste. The Staff Working Document (SWD) accompanying the Commission’s Communication3 further details these issues in 8 sets of options. In relation with the issues raised by the Commission in these two documents, this paper develops our main demands to address the interface between chemicals, products and waste, and includes issues that go beyond those exposed by the Commission…