To achieve a circular economy it is essential to recycle substances, materials and products created by that economy. Recycling, however, becomes more difficult when said materials and products contain substances that are so hazardous that their use is restricted. This is the case with any substance that is identified under the REACH Regulation as a 'substance of very high concern' (SVHC). Products containing SVHCs can only be used when their use is specifically authorised. Producers are concerned that their recycling practices and the use of recycled waste will become more difficult if the waste contains SVHCs.
This was the conclusion drawn from a series of interviews with producers and sector organisations about bottlenecks, and possible solutions, conducted by RIVM. One challenge facing parties involved in the responsible reuse of waste is the current uncertainty surrounding the boundaries of the Waste Framework Directive and those of REACH: when does waste become a substance, a mixture or an article? Under REACH, permission for the safe use must be obtained; this requires significant information to be provided on the composition of the material, information that is often not available in great detail. There is still a lot of uncertainty about the SVHCs present in waste streams, potential future SVHCs and exactly when permission for safe use should be applied for.
The companies interviewed also stressed how essential it was to separate waste which contains SVHCs from SVHC-free waste streams in an early phase of the waste recycling process, a practice which also requires detailed knowledge of the SVHCs present in waste. The companies indicate that regulatory or financial incentives may be needed to stimulate the implementation of separation processes that are less economically feasible.
Finally, it's very important to develop applications in which recycled material containing SVHCs can be used safely. One example hereof is the three-layered sandwich PVC tube which has a middle layer containing SVHCs but two outer layers made from SVHC-free material which protects humans and the environment from any risk of exposure.