Comments on Stakeholder Consultation Paper - interface of chemical, product and waste legislation

ClientEarth responds to the European Commission's consultation on the interface of chemical, product, and waste legislation. The organization argues that circular economy goals should not override human health and environmental protections, warning against 'differential treatment' for recycled materials in REACH restrictions. It calls for improved information systems on chemical compositions, stricter enforcement of REACH Article 33 regarding consumer information, and a focus on preventing hazardous chemicals from entering the economic cycle to ensure the long-term viability of recycling.

• ClientEarth argues that the European Commission's focus on removing 'legislative barriers' to the circular economy must not treat the non-toxic environment strategy as an ancillary piece of work, as both objectives are required to be pursued in parallel under the Seventh Environmental Action Programme.
• To address insufficient information about substances of concern, ClientEarth proposes a two-staged strategy: a long-term new information system providing full chemical compositions to economic operators, and short-to-medium term improvements including the enforcement of REACH Article 33 and extending information obligations to all hazardous substances.
• ClientEarth expresses concern that the Consultation Paper may prioritize economic benefits of circularity over health and environmental protections, specifically criticizing the possibility of 'differential treatment' (more lenient restrictions) for materials recovered from waste under REACH.
• The document identifies gaps in EU waste classification, noting that classification is often based on the origin of waste rather than chemical composition, and that hazardous properties under the Waste Framework Directive exclude certain hazards identified under REACH, such as endocrine disruptors, PBT, or vPvB.
• ClientEarth recommends limiting the entry of hazardous chemicals into the economy to ensure future recyclability, suggesting the acceleration of SVHC identification, the creation of a common online platform for safer alternatives, and stricter enforcement of consumer information obligations.

APA

ClientEarth (2017). Comments on Stakeholder Consultation Paper - interface of chemical, product and waste legislation. https://www.clientearth.org/media/x1vdgdzs/comments-on-stakeholder-consultation-paper-interface-of-chemical-product-and-waste-legislation-ce-en.pdf

Chicago

ClientEarth. Comments on Stakeholder Consultation Paper - interface of chemical, product and waste legislation. 2017. https://www.clientearth.org/media/x1vdgdzs/comments-on-stakeholder-consultation-paper-interface-of-chemical-product-and-waste-legislation-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Comments on Stakeholder Consultation Paper - interface of chemical, product and waste legislation |date=July 2017 |url=https://www.clientearth.org/media/x1vdgdzs/comments-on-stakeholder-consultation-paper-interface-of-chemical-product-and-waste-legislation-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2017comments, author = {{ClientEarth}}, title = {{Comments on Stakeholder Consultation Paper - interface of chemical, product and waste legislation}}, publisher = {ClientEarth}, year = {2017}, month = jul, url = {https://www.clientearth.org/media/x1vdgdzs/comments-on-stakeholder-consultation-paper-interface-of-chemical-product-and-waste-legislation-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }