Transparency of chemical information in materials and products is a foundation stone for a well-functioning plastic treatyFeatured
For the second session of the Intergovernmental Negotiating Committee to develop an international legally binding instrument on plastic pollution, including in the marine environment, HEJSupport, SSNC and groundWorkSA prepared a submission describing potential options for elements towards an international legally binding instrument.
We believe that a foundation stone for a well-functioning treaty will be a mandatory globally harmonized requirement for transparency of information on chemicals and polymers in plastics. The requirement should, thus, be in the core text of the treaty as a legally binding stand-alone article on a globally harmonized requirement on transparency of information on chemicals in plastic materials and products throughout the entire lifecycle in plastics value chains.
To start with, the identity of chemicals and polymers of particular concern should be disclosed throughout the entire lifecycle of plastics.
This will support the safe substitution of problematic chemicals, polymers, and materials containing them; the development of appropriate policy responses, including regulation with restrictions and bans; and spur innovation and design of plastic products suitable for a toxics-free circular economy.
To support informed decisions, including restrictions, bans, and substitution of hazardous chemicals, a globally harmonized public database on processing aids, additives and polymers in specific materials, products, and their components should be developed to implement the Article on transparency of chemical information.
A globally harmonized central data management system reduces costs for individual parties of the treaty and ensures equal access to data in globally harmonized formats. A detailed description of how the database should be filled in, who is responsible for its update and a living list of chemicals linked to specific products and their components should be in an Annex to the treaty.
With the adoption of the treaty text into national legislation and to collect harmonized information for the global database, countries can request manufacturers of plastic materials and items to tag their products, including product components, with the transparency information in an electronic tag, e.g. a QR code or another kind of electronic product passport. In this way, we can keep track of chemicals in the plastic components throughout their life cycles.
Lessons learnt on how such a public database and product passport system can be constructed and its challenges can be drawn from the EU, where the SCIP (substances of concern in products) database for all kinds of materials is already operational and electronic product passports are under development.
In addition, in our submission, we also highlight that dependency on fossil feedstocks for chemicals in society must decrease. Thus, there should be provisions in the treaty to restrict and, as soon as possible, phase out non-renewable feedstocks. However, replacing fossils with bio-based feedstocks for hazardous molecules should be considered a false solution because a molecule has the same inherent hazard properties irrespective of feedstock.
The submission was presented at the UNEP webinar on January 31. A two-minute recording is available below.