Following the publication of the European Green Deal (https://ec.europa.eu/info/files/communication-european-green-deal_en), the EU Commission is consulting stakeholders on its new Circular Economy Action Plan. (https://circulareconomy.europa.eu/platform/fr/node/2534).
HWE sent some proposals to the EU Commission expressing its view on how implementation of some key principles through an integrative and consistent approach will promote non toxic material cycles and preserve the high level of protection of human health and the environment within the European Union. Better environment for better health is key to reach a zero pollution ambition for a toxic free environment.
To this end, we would advocate the following recommendations:
- To ensure adequate implementation of the current legislation in a harmonised way within the EU Member States.
- To define substances of concern (SoC) and adopt an approach by grouping in their assessment, in the view of developing the EU market for secondary raw materials and address the issue of insufficient information regarding the presence or not in the recycled materials.
- To keep separate classifications for products and waste to preserve their respective challenges. If a risk based approach is relevant for products, the classification should take into account intrinsic properties of the waste – hazard based approach – when it comes to the waste stage, as the final destination of the waste is never known for sure.
- To trace the waste and ensure a decontamination step to contribute to clean material cycles. Separate the waste streams the most upstream in the chain should also be considered by the EU decision makers
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