The missing piece

Chemicals in Circular Economy

 6 Foreword
8 The Business opportunity in a circular economy
10 CASE: Apple

12 Product planning and design

14 CASE: H&M

16 Supply chain management, transparency

and traceability
18 CASE: Ikea

20 Legal compliance is not enough

22 CASE: Coop Denmark
2 3
24 Reuse and recycling
26 CASE: Sarp Industries
 Designing and manufacturing products
to be recycled is great. But there is one piece
missing in the circular economy debate
– hazardous chemicals.
Without proper attention to chemicals,
circular economy will never work.
4 5
6 Foreword 7

THE CONCEPT OF CIRCULAR ECONOMY has long been a staple today’s chemicals legislations are not adapted for a sustain­ The companies featured in this report – Apple, Coop Denmark, parency. Today, the chemical information that
in the vocabulary of anyone who wants to come across as at able circular economy, as many hazardous chemicals are H&M, Ikea and Sarp Industries – are perfect examples of this. follows a product in the world’s supply chains is
least somewhat progressive. What has changed in the last unregulated and in widespread use. These chemicals fulfill We are convinced that it is not a coincidence that these com­ lackluster. At best, companies only have a
couple of years is that this production model has started to thousands of different functions in all kinds of everyday panies are in many cases market leaders in their respective vague idea of the contents of their products.
gain traction with people who have the mandate to actually household items all around us. And as these items are the industry. If your company is on the move towards adaptation
make it happen. Policymakers all over Europe, and elsewhere, very same we recycle and turn into new products in a circular of more circular business models, we believe this publication LOW CHEMICAL STANDARDS will only serve
are already in the drafting stage of several circular frame­ world, it also means we are recycling their toxic contents. can help you gain some insights and inspiration. to alienate innovative and progressive
works and a growing number of businesses are on the move companies from recycled materials
too. Today, circular economy is more than just a buzzword. Luckily, a growing number of brands and retailers are realis­ AND POLICY MAKERS, there are important messages in this altogether. Ask yourself:
ing that, at the moment, legal compliance is neither a good publication for you to take home as well: Stop focusing just
How will a circular economy work if
ONE CRUCIAL, BUT OFTEN OVERLOOKED PART of a circular benchmark for corporate chemicals management nor for a on the quantity of recycled materials and start thinking about
no one wants to buy and use
economy is the role of chemicals. As the progressives of the circular economy. In order to account for weak legislation the quality. Create policies that favour sustainable innovation
recycled materials?
world seem intent on solving the problems of pollution and stay away from toxic chemicals in products and supply – not the opposite. That means picking up the pace and
and depletion of the earth’s resources by simply increas­ chains, many companies have internal chemical require­ banning the use of obvious problematic substances
ing recycling, little attention is paid to the contents of the ments that go beyond legal compliance. and elevate the requirements for chemical tran­s-
old products that we turn into new ones. The truth is that
 The business opportunity
in a Circular Economy
In essence, a circular economy can be described as a But wait a minute, you say. There are well known brands out
change in the way that companies make profit. there that turn their old products into new ones. Yes, that is
CHEMICALS ACTUALLY PLAY A LARGER ROLE in a circular eco­ correct. Apple, for example, even pays money for customers
Instead of selling material volumes that are
nomy than one might first think. How so? to bring back their old phones, which are then used to make
ultimately discarded in the trash, you sell material
new ones. But in this case, Apple is in full control all the time.
functions that may be used over and over in a Since hazardous chemicals are common ingredients in all It created the original phone and knows it fulfills Apple’s
8 perpetual cycle. THE IDEA OF A CIRCULAR ECONOMY is to manufacture com­ kinds of materials they obviously end up in recycled materials chemical requirements. Hence the old phone can be used to 9
ponents, articles and products that can be perpetually dis­ as well. This fact makes it virtually impossible to grow the make a new phone. This is called a closed waste loop. Closed
When you think about it, the existing linear economy based assembled and re-used, thus creating a no-waste society and market for recycled materials – the material transparency is waste loops are great, but they are still not enough to create
on selling volumes and wasting resources is actually ludi­ minimising the strain on natural resources. To simply use and simply too low for chemically progressive brands to want to a global circular economy.
crous. Try explaining the rationality behind the concept of discard is no longer a viable option. To achieve this change, re-use these materials in new products.
planned obsolescence to a child, for example. “That’s right, however, both businesses and society need to re-think the THE WAY FORWARD IS INCREASED TRANSPARENCY on the
we intentionally design many products with a short life, way we make profits and design products. HAZARDOUS CHEMICALS IN PRODUCTS AND SUPPLY CHAINS chemical contents of all materials. This information should
includ­ing light bulbs and printers, in order to force people to are not only a real threat to human health and the environ­ follow materials all the way to the waste phase. Used pro­
buy new ones”. But this can only go on as long as virgin ma­ In business, sustainability is sometimes seen as a parallel ment, they also pose a reputational liability. A growing perly it will raise the price of recycled materials.
terials are available, and as long as society and its taxpayers ­activity – a necessary but nevertheless burdensome cost – number of brands and retailers understand that hazardous
accept paying for negative externalities such as waste and not something that actually strengthens the business idea substances mean exposing customers to a risk – or a per­ THE END GOAL IS TO ELIMINATE HAZARDOUS CHEMICALS
pollution. For how long will this be accepted? and profitability. In a sound circular economy, companies ceived risk, which can be just as devastating for the brand. ­­To from waste streams through design and innovation, not dilu­
prosper due to environmental success, not despite it. account for this risk, many of the world’s most well known tion and costly risk analyses. Strict risk approaches will only
In our society, the prices of raw materials and trash collection brands have their own internal requirements stating which create a liability and postpone dealing with the root of the
are increasing because of simple physical limitations. The re­ There is a need for a change in the business mindset, so chemicals are allowed in their products, requirements that go problem, which is contaminated material streams. Instead,
sources available in the earth’s crust are simply shrinking. The that company interests, societal needs and environmental beyond what is needed for legal compliance. the same requirements should be applied to all material
“take, make, waste” paradigm within the linear economy has challenges are merged into one business idea. We should streams, regardless of origin. The use of recycled material can
led us to a critical point that also affects business, through stop talking about the need to balance economical, environ­ Unfortunately, except for very specific cases, recycled materi­ only be profitable in the long run for a company if it fulfills
higher commodity prices and higher volatility. This will lower mental and societal interests, as there is no contradiction als cannot meet such requirements today. the same criteria as virgin material.
margins and profitability for companies and increase consu­ between the three.
mer prices in the long run.
 Case: Apple
“The goal is to one day make our products
using only recycled or renewable resources”

How does Apple i­ncorporate materials we use in our products are sourc­ and sorts components and can take apart
including the new iPhone XS and XR, with Do you see any financial
no reduction in quality or performance. This
the concept of circular
ed responsibly through strict standards and up to 200 iPhone devices per hour. This way
one change will prevent the mining of over
­benefits of incorporating
programs that drive positive change. we can recover materials that traditional
­economy into its business? 10,000 tons of tin ore a year. circular economy into the
recyclers can’t – and at a higher quality. By
10 meticulously disassembling our products, core business idea? 11
Apple is committed to finding ways to use And with the new MacBook Air, we recently
we can direct components and materials
less of the planet’s precious resources, and introduced our first computer with an Upfront investments, like Apple’s develop­
You have developed robots to those recyclers who can recover the im­
enclosure made from 100% recycled ment in robots like Liam and Daisy, are
recover more materials for reuse. As part of portant parts. These materials will then be
this commitment, we recently announced to help you disassemble your sent back into secondary materials markets,
aluminium. To do this, Apple had to create necessary to achieve circularity. Like
a goal to one day make our products using smartphones. Why? closing the loop on these materials and
an aluminium alloy that delivers the same everything at Apple, this effort is driven
only recycled or renewable resources, and strength, durability and finish without by innovation. Through more efficient re­
reducing the need to mine more resources
return an equivalent amount of material min­ing any new aluminium from the earth. cycling technologies and other innovations,
As part of our closed-loop goal, we’re work­ from the earth.
back to the market to be used by us or Instead we use shavings of recaptured we hope that one day we can stop mining
ing to recover as many materials as possible
others. aluminium that are re-engineered down the earth altogether.
from our products and return them to the
to the atomic level. The result is a beautiful
global supply chain. Existing techniques,
To meet this ambitious goal, we’re applying and strong enclosure, and a product with
such as shredding, recover only a few
Could you give examples of 47% lower carbon emissions compared to
the same innovation that goes into our pro­ kinds of materials and often diminish their
ducts into piloting new recycling techno­ quality. There is a clear need for innovation recycled materials that you the previous generation.
logies. We recognize this effort will require when it comes to techniques that are able use in your products?
years of collaboration across different Apple to separate and recycle complex mixtures
teams and our suppliers, as well as with of materials. We’re just getting started in our efforts, but
recyclers, but our work is already underway. we’ve already made some notable progress.
While we transition to this new supply Based on the learnings from our R&D This past fall, for example, we announced
chain model, we are committed to main­ project “Liam”, we developed “Daisy” – our we have transitioned to using 100% recycl­
taining our initiatives that ensure that the newest disassembly robot. Daisy removes ed tin in the main logic board of iPhone — ­
 Product planning and design DEPENDING ON COMPANY GOALS, chemical issues can be prio­
ritised at different levels. At the lowest, so-called reactive level
you simply follow regulations and adapt on the fly. By contrast, at
the highest and most ambitious level you actively seek out green
A smart design is the most critical stage in a chemistry and sustainable materials that position the organisa­
tion for the circular economy. This kind of work means that you are
product’s life cycle. The fate of the life cycle is
working with positive selection of chemicals. Simply replacing an
determined here, right at the start. The most undesirable chemical with another that is not yet regulated, is of
cost-effective approach is to select the appropriate similar quality or poorly investigated, is not enough.
materials and chemicals right at the drawing board,
PHASING OUT UNWANTED SUBSTANCES from production should be
before the product even exists. By doing this, toxic
followed by product development that aims to meet the needs of a
12 waste can simply be “designed out” and instead circular economy. The solution is not necessarily another chemical. 13
replaced by resources and products that can be A substitute for a flame retardant could be a sprinkler or a material
utilised by somebody else. that is not flammable, such as a metal. Instead of using hazardous
plastic softeners such as phthalates, it is often smarter to use an­
other type of plastic or a material that is naturally soft.
THE GREATEST OBSTACLES TO SUCCESSFUL RECYCLING are actually
the original design and lack of information about what chemicals Other solutions can be found by thinking outside the box and
were added to the materials from the very beginning. By demon­ ­questioning dogmatic preconceptions, behaviour and routines.
strating knowledge and transparency you add value to the product.
Products and materials that are designed to be recoverable, recondi­ It doesn’t take a rocket scientist to understand that by decreasing CHEMICALS MANAGEMENT SHOULD HAVE A HIGHER PRIORITY Some outdoor jackets with hazardous fluorinated PFAS materials are
tioned and upgraded have around twice the value of products and the hazardous content of a product, you increase the possibilities for on the corporate agenda. Chemical issues cannot be the responsibi­ often sold with arguments that the jacket can handle heavy rain for
materials that are not, as they can be sold several times. recycling and success in the aftermarket. You also reduce the need lity of a supporting department that has a weak mandate within an up to two weeks. But who needs this jacket? Even in places where
for virgin raw materials and the energy costs to produce them. organisation. This problem can be illustrated by the fashion industry. there is heavy rain most people will normally not stay outside 24
Product planning and design in a circular world is about foreseeing Who do you think has the last say when designing a product within hours a day for two weeks straight. If this is you, you should probably
and meeting the life cycle management challenges of many dif­ ELIMINATING HAZARDOUS SUBSTANCES FROM PRODUCTS could a fashion company – the designers or the chemicals department? start looking for a wet suit instead.
ferent groups of people that will come in contact with the product, lead us closer to solutions to many other environmental threats as The designers, of course. Progressive fashion companies have solved
such as retailers, consumers and recyclers. It should also take into well. When demand for virgin materials decreases due to effective this by either educating their designers about chemicals, or simply CHANGING BEHAVIOURS, CULTURES AND RAISING CONSUMER
account the various services the product will require, such as spare and non-toxic life cycles, the pressure on natural resources will most giving them a set of pre-approved materials to work with. awareness may sound frustratingly vague, but shouldn’t be sneered
parts, components and repairs. For instance it is at this stage a likely decrease. The novel idea that the circular economy presents is at. Removing over-the-top features from products, while simul­
designer can enable dismantling, by making it easy to separate that good design is not only environmentally and morally good; it’s In such cases, chemicals have gained higher priority in strategic taneously communicating the environmental reasons for doing so,
different materials that can then enter the appropriate waste also more profitable. Bad design, on the other hand, is expensive as ­business decisions and organisations have created policies that can work wonders.
streams. it only creates useless waste at the end of a product’s life cycle. guide towards a more proactive approach.
 Interview with Anna Biverstål, Global Chemical Compliance Expert

Case: H&M
“We need to be certain
that the chemicals we use
are safe”

Why is it important to focus Does H&M think about What is the reason for Why did you make this
on chemicals in a circular ­chemicals right at the implementing this positive list? change?
14 ­economy? product planning stage? 15
Well, until fairly recently, we were very keen To be able to phase out hazardous sub­
A circular economy is so much more than Yes. We have initiated a process of develop­ on restricting hazardous substances in our stances you first need to find something that
just recycling whatever we can. We need to ing and implementing a positive list that will products – and we still are – but lately we is better, and in this process we, and many
be proactive and really know what chemicals make it possible for us to consider chemicals have changed focus. Instead of focusing only other brands, came to the conclusion that a
we are using in our products, otherwise toxic right from the design phase. The aim is to on what not to use, we now focus on what hazard-based screening method really helps.
chemicals will circulate around and around design a garment with only preferred chemi­ we should use. With this screening process we can select
endlessly. We therefore need to be certain cals from our positive list. which chemicals to use fairly easily, and by
that the chemicals we use are safe. And the way we do this is by working with using a third-party certifier it makes the
This method is not fully implemented yet, positive lists, which are essentially lists that whole process comparable and more trust­
For H&M, it is also completely necessary but we are getting there. specify which chemicals we should use in worthy in our opinion.
to focus on chemicals in order to meet it´s our products. A couple of months ago we
ambition of becoming 100 percent circular. re-launched this method with clearer criteria We thought about developing our own
for the chemicals. This was done together ­method of evaluating alternatives, but we
with several other well-known fashion truly believe that cooperation is the way
brands and a third-party certifier that uses a to drive change in this matter. The fashion
hazard-based screening method to evaluate industry is leaning more and more towards
the chemicals. I should also mention that sharing methods like this, and we think this
our list is public for anyone to see. is great. Hopefully, in the future, we will
agree on one single method for all of us.
 Supply chain management,
transparency and traceability
SYSTEMS LIKE THIS CAN BE USED to include extensive chemical infor­ allowing designers and and suppliers to use only well-known chemi­
Chinese whispers is a classic game for children There are mainly two activities that are needed in order to approach
mation. The barcode system is another such example. It is technically cals and materials that are suitable for recycling and/or composting.
the circular economy from a chemical point of view:
where the first person in a line whispers a sentence very easy to include chemical information in a system like this; all you
1. Increase knowledge of the composition of products, and
to the next person, and so on. When the last person need is the information. The challenge lies in implementation and This change is actually happening already, as many brands with big
2. Phase out chemicals that do not fit within a circular economy. standardisation. purchasing power are pushing for more and more chemical transpa­
in line repeats the sentence they heard it is likely
rency in the supply chain. By putting pressure on suppliers to increase
to have changed drastically. This is often exactly If you don’t know what chemicals have been added or used during Notwithstanding the challenges, a fully developed barcode system chemical transparency and use safer alternatives, these companies
16 how chemical information and transparency in the production you can’t claim that your products are safe. If you want or the like that includes chemical information holds countless pos­ serve as role models and pave the way for other, smaller companies 17
supply chain are handled. to prime your company for a circular economy, and at the same time sibilities. Imagine, for example, consumers being able to scan the to follow suit. They will also be more profitable than their competi­
reduce your business risk: Gain better control over your products, barcodes of everyday products with their smartphones and making tors when consumers can act on the chemical content and choose
improve content declarations, and increase the competence and more informed purchases. This future is not so far-fetched – the only safer products.
Since a product consists of components that are produced and as­ reliability of those upstream in your life cycle chain. This will increase thing lacking is the chemical information.
sembled by many different suppliers in the supply chain, it is impos­ your product’s recycling value.
sible to communicate the chemical content down the supply chain Companies that are well equipped for the future understand that
without proper information from the previous suppliers. SOME INDUSTRIES HAVE ALREADY CREATED EFFECTIVE SYSTEMS for this change is coming and will start making new kinds of demands,
transferring information between suppliers and users in the supply
THE NEED FOR SYSTEMATIC CHEMICAL CONTROL up and down chain. The IMDS and BOM-check databases are already used in the
the supply chain is already a priority for many companies. Unsur­ automotive industry and the electronic industry respectively, and
prisingly this need will only grow in the future as recycled materials relevant parts may be accessed by everyone in the entire supply
are being circulated back into the production loop. chain. These industries have an advantage and are in general better
equipped for the future requirements of transparency. Having said
this, there is nothing preventing individual companies from taking
these initiatives.
 Interview with Therese Lilliebladh, Chemical Specialist Team Manager

Case: Ikea
“A circular economy is both a responsibility
and a business opportunity”
What does a circular economy with the right quality that do not contain burdens, to promote compliance and give
harmful chemicals. businesses of all sizes, big and small, the
mean to Ikea? possibility to participate in the transforma­
Only one million tons of our recycled tion.
For us, a circular economy is both a
materials come from our own stores, so we
respons­ibility and a business opportunity.
must learn how to access external waste
And the way we go about this is to work
towards a business that is circular in all as­
and reuse it. However, sourcing recycled What lies in the near future
18 pects. In everything, from how we develop
materials in the quantities we need for
for Ikea in terms of a circular 19
our business is difficult due to the lack of
products and services, source materials,
infrastructure in many markets. Lack of economy?
develop supply chains and set up logistics,
­synergies in legislation and working pro­
to how and where we meet our customers.
cesses between markets further complica­ Our starting point for moving towards be­
te the possibilities to secure high volumes coming circular is our commitment to offer
As of now, we have 64 percent renewable
of these materials. 100-percent circular products and use only
and 8 percent recycled materials in our
renewable or recycled materials by 2030.
entire product range. Our aim is to use only
This means that in the near future we will
renewable or recycled materials by the year
2030. Is there anything in particular try to develop all products according to our
circular design principles. This includes, for
that legislators should think example, designing for an expected life­
about regarding recycled span, for recycling, for the use of renewable
What are the challenges materials and a circular or recycled materials, and for production.
of using more recycled economy? Right now, we are also exploring how to
materials? track legacy chemicals, and one of our
Yes, one key contribution would be to ­commitments for the future is to join for­
Well, Ikea does not accept that recycling enable transparency and availability of ces with others to develop new solutions
should happen at the expense of chemical recycled materials by setting up a harmon­ for dealing with chemicals during reuse,
safety – we want to secure a toxic-free ised cross-border legislative framework. refurbishment, remanufacturing and
circulation of materials. When we use re­
recycling.
cycled materials that are not from Ikea the It would also be beneficial to set simple
challenge is to find secondary materials reporting criteria, limiting administrative
 Legal compliance
is not enough
20 21
an enormous amount of hazardous chemicals are entering the EU via THE SUCCESS OF THE CIRCULAR ECONOMY LIES instead right at the
Just as hazardous man-made chemicals are com- use, and requires companies that market chemicals to present a set
products that will be used and finally become waste in the EU. beginning. In order to know what is in recycled materials, we need to
of test data. The US equivalent, TSCA (Toxic Substances Control Act),
plex and wide reaching, so is the legislation set up know what went into the virgin materials. Recycled materials need
set some basic requirements but is much more limited in scope. In
to regulate them. This was not always the case. For many other parts of the world there are other regulations in place
The regulatory system for chemical control is therefore not a reliable to comply with the same requirements as virgin materials in order
decades chemicals were hardly regulated at all, with to address chemicals, some aiming to be similar to REACH or TSCA.
guide for sustainable business or for identifying which substances to make them attractive in the marketplace. This is achieved with
are compatible with a circular economy. strong chemicals legislation and a high level of transparency.
some specific exceptions such as pharmaceuticals, There are also many product-specific regulations in the EU and in
pesticides and food additives. other regions for controlling hazardous substances in products such
THIS IS WHY CHEMICALLY PROGRESSIVE COMPANIES are setting
as electronics. The ambitions vary, but generally speaking the EU
the bar higher than legislation and enforcing their own chemical
sets the highest bar.
requirements for products and supply chains. The number of such
The vast majority of chemicals could be used without the need to companies with their own chemical standards is increasing, and
provide any information about them, their intrinsic properties or BUT EVEN THOUGH LEGISLATION HAS GONE from being extremely
today represents sizeable chunks of their respective industries.
the risk of using them. If a substance was identified as problema­ rudimentary, to at least trying to limit the use of hazardous sub­
tic, it was more likely to be a result of coincidence than systematic stances, it doesn’t mean that legal compliance guarantees automa­
Legislators might be tempted to make exceptions for hazardous che­
scrutiny. No general testing of chemicals for harmful properties was tic success in the circular market. In fact, this is far from the truth.
micals in recycled materials in order to meet recycling goals and high
required. Even in the EU, which in many ways has the most ambitious che­
circular economy ambitions. This will not only result in a growing
mical regulation in place, substances with hazardous properties are
supply of recycled materials containing hazardous chemicals, but
This has changed in recent years. The EU has enforced REACH (Re­ still in widespread use. This is because regulation moves slowly and
it will also hamper the market potential for second-hand materials
gistration, Evaluation, Authorisation and Restriction of Chemicals), it will take many years before REACH includes all the substances it
as more and more companies ask for materials that do not contain
a comprehensive legal framework that addresses all chemicals in intends to regulate. In addition, REACH does not fully cover the che­
hazardous chemicals.
mical content in articles that are imported into the EU. This means
 Interview with Malene Teller-Blume, Quality Manager

Case: Coop Denmark

“We try to go the extra mile and actually do
more than what the law requires”

Coop applies a stricter Coop recently ran a petition The campaign resulted in But isn’t your core business Could other companies learn
­approach to chemicals campaign in Denmark, calling Coop handing over a bill idea to sell food items and from your approach?
than the legislation calls for. for stricter chemicals legisla- that legislators signed. How make money?
22 There are already well known brands out 23
What is the business logic tion. Why did you do this? come the campaign was so there that have similar approaches. Look at
Yes, but I have never seen any proof that
behind that? successful? these campaigns have hurt Coop’s sales. On
H&M, Lego and Ikea, for example. Three very
One thing that separates Coop from other strong brands with a really good reputation,
retailers is that it wants to be part of the the contrary, we have a strong belief they
A few years ago we asked our custo­ I think it was because we managed to alert especially in terms of chemicals. But like us,
public debate and express its opinions, actually supports Coop’s reputation and our
mers which topic they felt was the most the public about how important chemicals they have worked for many years with these
and even try to affect policymakers. For ex­ consumers’ trust in us, and that they give us
important for Coop to tackle. The number are, without using any scare tactics. Ins­ questions. There needs to be a true sincerity
ample, Coop has criticised the authorities a competitive advantage. But it has taken
one thing customers mentioned was tead, the campaign leaned on science and when a brand starts talking openly about
for soft legislation on issues such as animal some time to get to this point. Now, when
unwanted chemicals in products, and since was presented in a balanced way. chemicals, and that takes time to establish.
welfare and tobacco. So this approach Coop speaks up publicly, consumers know we
Coop is a member-owned cooperative, Coop has tried to do more than simply
applies to a wide range of topics, not only are not simply doing it as a PR stunt, but that
these concerns need to be dealt with. But comply with legislation for over 50 years. You
chemicals. Because of this, Coop’s media we are serious about the issues we bring up.
apart from that – there are also strong need patience. At the moment competition
business arguments. Danes in general are activity, campaigning and presence in the in the Danish retail market is very tough, but
very concerned about toxic chemicals. If public debate actually resemble that of an I believe that Coop’s honest approach to che­
Coop can show that it is trying to go the NGO many times. micals and other important issues will help
extra mile and actually do more than what see it draw the longest straw in the end.
the law requires, then I think this can be an
important factor when consumers choose
between our competitors and us.
 Maersk Line, which is a world-leading shipping line, uses enormous amounts of steel
of different grades in its ships. The grade and composition of the steel varies depend­
ing on whether it is used on the deck, in the engine, in propellers, or the hull. By care-
fully documenting each piece of steel, each bolt or rivet, Maersk has calculat­ed the
second-hand value of the ship is increased by at least 10%. When the ship is finally

Reuse and recycling

scrapped, the components can be used in an optimal way.

In today’s society it is common to see products hazard-based approach, which only takes into consideration the Unfortunately, there is a trend to focus more on recycling
intrinsic properties of the waste. targets than on eliminating hazardous chemicals. Recycling
claiming to be 100 percent recyclable, or made out
targets should never be achieved at the expense of health
24 of recyclable materials, and so on. While this is in WHEN WASTE IS RECYCLED we can make a distinction between safe and the environment. The risks of chemical scandals due Fact box: What about incineration? 25
general very positive, it actually shifts focus from loop and unsafe loop systems. Safe loop systems are either closed to poor, low-cost recycling practices can be avoided for the
In this report we do not include incineration in the
loop systems (the material is completely traced and reprocessed for future.
the really important question: What is in the term recycling, even though some refer to incine­
the same purposes) or controlled loop systems (the waste material ration as energy recycling. The reason we consider
recycled material? is completely traced but can be reprocessed for different purposes). LEGALLY, IN ORDER TO INCENTIVISE HIGH-QUALITY it important to keep the terms apart is because
In both cases substances of concern are known and flagged so they RECYCLING, there is a need to avoid creating a two-tier sys­ incineration of waste means the resource is lost.
can only be incorporated for allowed uses. tem between virgin and raw materials, or between products What’s more, it contributes to climate change
MANY WASTE STREAMS CONTAIN HAZARDOUS SUBSTANCES and
and articles imported from the EU and those imported from and waste that contains hazardous substances,
should not be recycled without a prior decontamination step.
Unsafe loop systems, on the other hand, consist of waste mate­ elsewhere. for example chlorine and persistent pollu­
rials from different sources and for different applications that tants are converted to HCI and dioxins when
In current business models, recycled materials struggle to be compe­ incinerated. Keeping all this in mind, ChemSec
have already undergone an initial stage of mixing, blending and/ The same rules should apply – recycling should never be
titive with primary raw materials markets. This is often due to the acknowledges that in certain circumstances
or s­ hredding. In this case it is impossible to trace substances of viewed as a low-cost solution. It might sound contradictory,
fact that recyclers cannot deliver the level of material transparency incineration is needed to eliminate unwanted
concern and thus to ensure that the recycled material can be safely but setting identical, strict rules for recycled materials will
that many brands are asking for. substances from material streams and to
used. Unfortunately, this is the most common practice prior to help them compete with virgin materials.
avoid landfill.
recycling.
RECYCLING MARKETS CAN ONLY BE SUSTAINABLE if they can assure At these times, however, it should be done
IT IS A FACT THAT REGULATION DRIVES INNOVATION, and
that recycled materials do not contain toxic substances. Willingness using the best available technique to
THE CONSEQUENCE OF MIXING/BLENDING/SHREDDING WASTE recycling is no exception. Providing clear guidance in the
to support the development of non-toxic material cycles will thus reduce pollution. It is crucial that all waste
before recycling is dilution of the substances of concern. Safe shape of strict r­ egulation would eventually be beneficial for
not only protect health and the environment but will also enhance manage­ment parties contribute to solve this
­removal of the substances becomes technically and economi­ brands, suppliers and consumers. Putting the appropriate complex issue in the most beneficial way for
the quality of secondary raw materials and boost recycling markets.
cally impossible and ultimately increases the background level of legislation in place is not a burden, it will provide clarity and human health and the environment, using
­unwanted substances in all goods. is essential to establish a circular economy. the most appropriate technique for each
Generally, we have no prior knowledge about the final use of a waste category.
recycled material. This is why it is extremely important to apply a
 Interview with Cédric L’Elchat, CEO What kind of changes would
you like to see in production
Case: Sarp Industries processes in order for Sarpi to
deliver even better, non-toxic,
recycled materials?
“There is a need for incentives The dream we have, and that I think we

that encourage the quality of recycling, share with many recyclers, is to have closer
relationships with producers of goods so

not the quantity”

we can plan for waste treatment right from
the start. The aim of this relationship would
not be simply to allocate legal or financial
responsibilities for the waste, but rather to
improve the way we can recover and recycle
products. We could, for example, point out
substances and components that are pro­
blematic from a recycling standpoint right at
the design stage.
26 How do you know which Does the recycling industry So it’s impossible to achieve 27
materials contain toxic sub- have any use for more infor- a circular economy free from
stances and which do not? mation about the chemical hazardous chemicals? What should legislators think of
content of goods? in terms of a circular economy?
Since we are experts in recycling hazardous No, not at all. Right now we have a great
waste, people only come to us when they chance to change the business model and They should not only consider the amount
Yes, at Sarpi we are always looking to
are certain that materials contain hazar­ look towards innovation. There are many of materials being recycled, but more the
extend our knowledge. That’s why we are
dous substances, so that takes a large part great techniques out there but there is a quality of recycled materials. Decontamina­
really pushing for things like Echa’s waste
of the guesswork out of it. In those cases reluctance to accept the initially higher tion is essential when dealing with materials
database*. An initiative like this will greatly
where we can’t get the complete picture, cost. But looking ahead, if we want to get containing substances of concern. At the
help to push all producers of materials to
we look at the origin of the waste and the completely rid of toxic substances in re­ moment, everybody is focusing on what
increase their transparency about chemi­
processes it has likely gone through. This cycled materials, there need to be incen­ proportion of materials is being recycled
cals of concern. Of course, there’s a wide­
gives us an idea of the kind of chemicals tives like this that encourage the quality of and how to increase this, without looking at
spread reluctance to share this informa­
that are present in the waste. Sometimes recycling, not the quantity. what we mean by recycling and the quality
tion, not only from the affected companies
we actually have to convince customers of the recycled products. This situation just
but also from politicians because it will ob­
that we should take care of materials that opens up the door to bad practices and cutt­
struct many recycling goals. And they are
are allegedly non-toxic, since we know ing corners.
probably right – it will. The problem with
from experience that these materials
these politically ambitious recycling goals
­usually contain hazardous chemicals.
is that they are set without any concern *In 2018, there was a EU proposal that the
for what is technically and economically European Chemicals Agency shoudl build a data-
feasible at the moment. base including all EU Candidate List chemicals in
all products placed on the EU market.
AS MORE AND MORE CORPORATIONS ARE MAKING GREEN PLEDGES FOR THE FUTURE,
the notion that there is a contradiction between being sustainable and profitable at
the same time is becoming increasingly outdated.

This is especially true in a circular economy, which should be viewed as a golden

­op­portunity to combine business opportunity with corporate responsibility. In this
publication there are portraits of several companies making the journey towards
circularity right now. Naturally, this transition will not happen overnight. There is
a lot of work to be done.

THE MOST IMPORTANT THING is to avoid hazardous substances in products and pro­
cesses a­ ltogether – preferably right from the design stage. Simply following legislation
is not enough as there are many substances in widespread use that are not fit for a
circular economy.

ACCEPT THAT NOT ALL MATERIALS SHOULD BE RECYCLED. This follows on from the fact

ChemSec March 2019 • A large majority of the great photos used for this publications are thanks to unsplash.com
that many substances that are legally OK to use are in fact hazardous. It also applies to
so-called legacy substances, which have been found unfit to use but are still present in
many materials with long lifecycles.

REGULATION NEEDS TO MOVE FASTER, not least to avoid creating “new” legacy sub­
stances in the future. A circular economy and progressive chemicals legislation go
hand in hand – one cannot prosper without the other. Strict legislation will not only
help avoid legacy substances, but it will also help drive the innovation of new, safer
alternatives to hazardous chemicals.

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