RISKCYCLE and EU Legislation

Abstract

RISKCYCLE is an artificial word which addresses the risks associated with the global recycling streams. As part of materials like waste paper, plastic, and electronics, pollutants and chemical additives are transported abroad, e.g., they are exported to emerging and developing countries. Here these pollutants/additives can cause risks for humans and the environment especially if treatment/recycling is performed on a lower technical standard. The specific risks that can occur have been studied in an international EU-funded research program, which is the basis of this publication.

At the end of such a project with important results, it is also the question: How can these results become part of a solution for this problem? For this purpose we have analyzed, which EU regulations have the ability to cover RISKCYCLE, namely for waste (WEEE, RoHs), product design (ecodesign), and chemicals (REACH). Finally, all regulations contain segments that are suitable to address RISKCYCLE. But the European chemicals legislation is the best sector to integrate the RISKCYCLE problem because of its sophisticated instrumental equipment.

It is shown that REACH today in principle has already many necessary instruments to tackle RISKCYCLE. So within the registration procedure of chemicals, the registrants have to include RISKCYCLE exposure scenarios. The guidance documents for the registration procedure cover the waste sector in a way that risks identified in connection with waste export in developing countries should be quantified and if necessary managed. But it is open, how these provisions are considered in reality.

Therefore the authors give some recommendations, how within REACH RISKCYCLE aspects could become a more binding part of the regulation.