HEJSupport, Centre for Environment, Justice and Development (CEJAD), Swedish Society for Nature Conservation (SSNC), and groundWork South Africa wrote a submission for the Ad hoc open‑ended working group (OEWG) to prepare for the intergovernmental negotiating committee on plastic pollution.
The submission, entitled “Mandatory Transparency Standard for Chemicals in Plastic Materials and Waste” is available on the OEWG website.
Circularity in material flows is a key strategy to address waste issues and improve resource efficiencies. This principle should be at the core of the new plastic treaty. However, recycling of plastic without transparency and disclosure of hazardous constituents will undermine the potential benefits of the circular economy because toxic chemicals hazardous to human health and the environment are at risk of being spread with recycled materials in uncontrolled ways.
Plastics potentially contain hazardous chemicals – both unreacted monomers and additives. Some additives may be POPs from legacy materials or POPs that have present exemptions in the Stockholm Convention; others may be other chemicals of concern, such as potential carcinogens, mutagens, reprotoxic, endocrine disruptive and neurotoxic chemicals. Spot checks and investigations – by governmental agencies as well as NGOs – have repeatedly shown the presence of hazardous and even banned chemicals in products from recycled plastics, including toys and food contact materials.
There can be no excuse for allowing recycling of materials with unknown chemical composition to enter into the circular economy. Doing things correctly from the beginning will help to avoid regret further down the road. For example, this insight is why there are now transparency requirements for chemicals in materials and articles in the EU – that is at the forefront of transforming the economy into a circular.
In our intervention, we have accounted for the necessity to include a mandatory transparency standard for the monomers used to formulate the plastics and the additives from the very beginning.
Including such a mandatory transparency standard in the plastic treaty will ensure the public right to information on hazardous chemicals in plastics and pave the way towards the end of the recirculation of toxic chemicals in new products.