Tuesday, the European Commission unveiled the long-awaited Plastics Strategy meant to address the plastic waste issue. The strategy set forth emphasised the circular economy while tackling important health and environmental aspects.
The strategy seems ambitious and aims to re-thinking the value chains, while advancing a multi -stakeholder approach in order to curb the waste generation and to re-inject secondary raw materials into the EU economy.
International cooperation is only mentioned in the perspective of plastics in the ocean. However, given the fact that supply chains are currently complex and dynamic ecosystems, far from the linear chains of the past, international cooperation can be given a more important dimension when it comes to environmental and health issues, but also to the “recyclability “of materials. Let us take a closer look to the long-debated issue of hazardous chemicals in articles, focusing on the plastic items on the EU market, most of them manufactured outside EU.
For imported articles, there are notification requirements if the items contain SVHC in concentrations above 0.1% by weight and more than 1 tonne/year importer. It is well known by now that this REACH provision has been so far very difficult (if not impossible) to enforce, for the simple reason that millions of products enter the EU customs every day and their physical verification is not achievable. Moreover, importers of articles are the last link in the supply chain, and many of them generally unaware that there is a chemical regulation that they need to comply with. At the end of life, these plastic articles will enter the waste streams, with the purpose of being recycled, but the presence of hazardous materials such as persistent organic substances or substances suspected to have endocrine disruptive properties (i.e. flame retardants, certain plasticisers, etc.) will render this waste non-fit for recycling – therefore condemned to incineration. In real life conditions, it will be impossible to trace where every piece of plastic in the waste stream originates, thus impossible to know what additives in in what concentrations have been used in the manufacturing process.
With the increase of information on individual chemical substances, as well as development and refining of analytical methods, it is reasonable to assume that many substances, nowadays presumed safe, will be deemed hazardous in the coming years and therefore their presence in the waste streams will hamper recycling. In such context, the investment in R&D to “decontaminate” the waste stream before recycling will most likely focus on legacy chemicals, lacking the dynamic necessary to cover the “new” and “upcoming” hazardous chemicals that will remain problematic. Moreover, waste stream decontamination will require the development of highly specialised infrastructure to collect specific waste streams, which will reflect directly in the cost of such processes, questioning the economic benefits. Actions on boosting the circular economy need to therefore consider the things in their entire complexity, ensuring predictability and economic viability of such investments.
From the health perspective, the microplastics in the environment are indeed an emerging issue at global scale. If the intentional use of plastic microbeads can be controlled through regulatory measures, it is less clear how the unintentionally generated microplastics (through wear and tear of products) can be tackled. It is hard to imagine that any regulation can put a threshold on the number of plastic particles released by a fleece jacket, or a tyre, or any other plastic item during its lifetime, no matter how comprehensive the durability testing might become.
Concerns over the presence of microplastics in drinking water will only increase the consumption of bottled water, despite of any actions targeted to modify consumer behaviour toward reducing it. The use of recycled materials for food contact applications is also a very sensitive matter, because it is virtually impossible to know the precise composition of every piece of material entering the waste stream. Specific tests will need to be developed and validated to ensure the absence of contaminants of concern from the recycled materials, and these will build costs. Use of recycled materials for food packaging can create fears and reluctance among consumers, whether justified or not.
All in all, the new strategy presents an ambitious list of actions but here and there the argumentation is conditional, due to the many variables involved (technical feasibility, economic viability, industry reactions and initiative, social impact, consumer behaviour, educational and social constraints, etc.). Remains to be seen to what extent all these ambitious actions can be achieved in such (relatively) short timeframe.
In today’s globalised economy, the EU Plastic Strategy may achieve its goals only if the international dimension is properly addressed.