Globally harmonized requirements for transparency and traceability of chemical information in plastic materials and products in the Plastic Treaty

At the side event on Plastic pollution, toxicity, chemicals, and potential risks to human health, HEJSupport, together with the Swedish Society for Nature Conservation and groundWork South Africa presented a vision on how globally harmonized requirements for transparency and traceability of chemical information in plastic materials and products should be included in the text of the Plastic Treaty.

The presented vision is already supported by more than 40 civil society organizations, including big networks and UN Women’s Major Group. In addition, in the Joint Ministerial Statement of the High Ambition Coalition to End Plastic Pollution, 56 ministers call for “binding provisions in the treaty to ensure reporting and transparency in production quantities, material, chemical and product composition, traceability and labelling across plastics value chains to provide the production and product information necessary to ensure accountability throughout the value chain.”

The future plastic treaty has a unique opportunity to become the first multilateral agreement with legally binding and globally harmonized requirements for transparency of information on chemicals and polymers in plastic materials and products and traceability of this information in individual products across the entire lifecycle of plastics and for all stakeholders in the value chain.

If this opportunity is realized, the treaty will not duplicate but complement existing environmental agreements on chemicals and waste. The need to control hazardous chemicals in plastics and include transparency of information about chemicals in plastics are among the critical requirements included in country submissions prepared for INC 2.

One of the reasons for this is that countries face challenges in effectively implementing those chemical and waste agreements, which do not have globally harmonized transparency and traceability requirements in their legal obligations. We already heard from Kei that there are gaps in these conventions regarding the lack of globally harmonized requirements on transparency and traceability of chemicals that need to be closed. Stockholm Convention on persistent organic pollutants (POPs) is one example. While listing new POPs for global elimination, countries simultaneously cannot agree to disclose these chemicals in products. We know just one example when an agreement was achieved to disclose a persistent organic pollutant in one type of product. No globally agreed information transparency standard and no globally harmonized requirements for tracking chemicals in individual materials and products in the POPs treaty undermine the effective implementation of the convention, for example, the safety of recycling because recyclers are deprived of making the right decision to ensure recyclates do not contain already banned substances.

To address countries’ concerns, the options paper for the plastic treaty now includes suggestions for increasing chemical transparency as part of possible core obligations.

A mandatory and globally harmonized chemical transparency mechanism should be developed for the plastic treaty to move this initiative forward. It should go hand in hand with traceability requirements for chemicals in individual products. Both are necessary precondition for a toxic-free circular plastics economy and resource efficiency. Chemical transparency and traceability are the foundation of the treaty because decision-making on nearly all its elements depends on this information.

Standalone inventory lists for additives, processing chemicals and polymers potentially found in various plastic types only give stakeholders a rough idea of the chemical composition of the materials to base informed decisions on.

A transparency mechanism, with a traceability requirement, will ensure that the disclosed information is linked to individual materials and products and can be tracked throughout their life cycles.

Compliance with lists of regulated chemicals and polymers is much easier if they can be tracked for individual materials and products.

Globally harmonized and legally binding transparency and traceability requirements for chemicals in materials and products also save time, money, and staff costs for compliance verifications in countries weak in resources. It internalizes the main cost to the manufacturers.

How should the transparency and traceability requirements be reflected in the Plastic Treaty?

First of all, we suggest including an article or an overarching target on transparency and traceability of chemicals and polymers in plastics in the core text of the treaty that will ensure that the requirements for chemical information transparency are

• Globally harmonized
• Legally binding
• Address the full lifecycle of plastics
• Make this information available and accessible to everyone in the value chain.

To achieve efficient implementation of such an article/target on transparency and traceability of chemicals, it is important to set up control measures/means of implementation are in place, including:

• An Annex on a globally harmonized transparency mechanism that includes thresholds for disclosure depending on how chemicals are considered, for example, based on grouping; a Transparency mechanism should also include criteria for identifying chemicals/groups of chemicals of concern to disclose. Only thresholds are needed for full information disclosure of all chemicals in plastics.
• A Database that includes data about chemicals in individual materials and products should be developed to facilitate informed decision-making for all life stages of plastic and all stakeholders in the value chain. The traceability of chemicals in individual materials and products should be based on transparency requirements.
• An Annex describing the approach towards chemical disclosure in plastics should be developed. It should answer such questions as, for example, WHO should disclose information (everyone along the supply chain)? How should it be done (using the mechanism with criteria already identified by the UNEP Chemicals in Products Programme, complemented by criteria to disclose information on polymers and disclosure concentration thresholds)? WHERE and HOW will information be stored (online public database)? WHO will host the data (The Secretariat of Treaty, IOMC, OECD, etc.)?​

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