A side event on the transparency and traceability of chemicals in products was held at the BRS COPs on May 7. It was organized by HEJSupport, SSNC, and groundWork South Africa, and moderated by Kei Ohno Woodall, Senior Coordination Officer at the Secretariat of the Basel, Rotterdam, and Stockholm Conventions.
There are many reasons why it is essential to know what chemicals are in products, stockpiles, and waste. This information helps identify potential health and environmental risks and ensures that products are safe for consumers and do not adversely affect the environment. It aids in managing risks associated with the use, disposal, and recycling of products, leading to safer handling practices and a toxic-free circular economy that does not recirculate hazardous chemicals. Additionally, it helps companies stay compliant with regulations and contributes to innovations and safer alternatives. Furthermore, providing information about chemical compositions builds consumer trust and allows for informed decision-making throughout the entire product lifecycle.
The following speakers presented at the event:
Olga Speranskaya, Alexandra Caterbow, Co-Directors, Health and Environment Justice Support (HEJSupport)
Peter Dawson, Chair of the Persistent Organic Pollutants Review Committee
Timo Seppälä, Senior Adviser, Centre for Sustainable Consumption and Production / Contaminants Unit, Finnish Environment Institute
Kei Ohno Woodall, Senior Coordination Officer at the Secretariat of the Basel, Rotterdam and Stockholm Conventions
Andreas Prevodnik, Senior Policy Advisor, Swedish Society for Nature Conservation (SSNC)
Rico Euripidou, Senior Manager, groundWork South Africa
Together, these experts examined the critical need for globally harmonized, legally binding systems to ensure transparency and traceability of hazardous chemicals, including in plastic products.
Through this publication, each speaker’s contribution is analyzed in depth, offering insights into:
- The current state of global and regional initiatives on chemical disclosure.
- The practical challenges of identifying Persistent Organic Pollutants (POPs) in products, waste, and stockpiles.
- Technological solutions for embedding traceability across supply chains.
- The disproportionate risks faced by low- and middle-income countries.
- Strategic recommendations for embedding traceability in the Global Plastics Treaty and broader international policy.
Olga Speranskaya
Olga Speranskaya, Co-Director of HEJSupport, opened the side event with a comprehensive and compelling presentation that framed the global challenge of chemical transparency in products. Her remarks set the tone for the entire session, emphasizing that chemical disclosure is a foundational component of a safe and sustainable circular economy.
Olga emphasized the importance of identifying the chemicals present in products, stockpiles, and waste to protect public health, support recycling, and ensure regulatory compliance. She argued that failing to disclose chemical content poses risks not only to consumers and workers but also to the broader environment, especially as materials are reused and reintroduced into supply chains.
She systematically walked through the global and regional frameworks currently shaping chemical disclosure. These included the Strategic Approach to International Chemicals Management (SAICM) Chemicals in Products Programme, which provides voluntary guidance for identifying and disclosing hazardous chemicals. Although an important starting point, she pointed out that this program lacks mandatory thresholds, which undermines its effectiveness.
Olga highlighted the Global Framework on Chemicals adopted in 2023 as a pivotal new development. This framework outlines strategic objectives that promote chemical transparency across the product lifecycle and aims to make chemical information publicly accessible. She connected this to emerging technical standards, such as the UNEP Global Framework for Digital Product Information and the UNECE Transparency Protocol—both of which are designed to digitize and harmonize the handling of chemical data.
On the regulatory front, Olga commended the European Union’s efforts, citing the SCIP database and the EcoDesign for Sustainable Products Regulation (ESPR), which includes a Digital Product Passport. She noted that these tools demonstrate feasibility and provide a model for global implementation.
Speranskaya also highlighted deficiencies in multilateral environmental agreements (MEAs), such as the Stockholm Convention on Persistent Organic Pollutants (POPs), which, despite its legal mandates, lacks consistent disclosure requirements. Only three POPs (HBCD, PCP, and PCB) have been subject to formal labelling guidance, leaving recyclers without the information needed to avoid toxic contamination caused by other POPs in products.
One of her most forward-looking contributions was the argument that the Global Plastics Treaty represents a “now or never” moment. By embedding chemical transparency and traceability provisions from the outset, rather than trying to retrofit them later, the treaty can help avoid the same pitfalls seen in other agreements. Olga’s message was clear: chemical transparency and traceability are achievable, necessary, and urgent.
Peter Dawson
Peter Dawson, Chair of the POPs Review Committee under the Stockholm Convention, followed Olga with a technically rich presentation that explored the operational and regulatory difficulties in identifying POPs in products, stockpiles, and waste.
He began by highlighting the extent to which POPs are already embedded in everyday consumer and industrial products. Out of the 37 substances listed under the Stockholm Convention, at least half are directly used in articles, particularly in plastic items such as electronics, vehicle components, textiles, and flame retardants. Many of these are not only widely used but also embedded in complex materials, making them difficult to trace and regulate.
Peter elaborated on how newly listed POPs tend to be more complex, with broader applications and longer exemption periods. He used the example of decaBDE, a flame retardant used extensively in vehicle interiors. Because vehicle parts have long replacement cycles, exemptions for these substances often extend over a decade, leading to ongoing exposure risks.
He referenced the recent mandate given to the POPs Review Committee by COP-11, which tasked them with developing viable strategies to identify POPs throughout their lifecycle. He described how the committee initiated a review, collected input from Parties and observers, and compiled findings into a report.
A key point of his presentation was the lack of harmonized terminology and inconsistent interpretations of what constitutes an “article,” a “stockpile,” or “waste.” These inconsistencies have profound implications for enforcement and compliance. For example, whether a single electronic wire containing a POP qualifies the entire appliance as a POP article remains contested.
Peter outlined several existing identification tools such as X-ray fluorescence screening, product databases like IMDS (used in the automotive sector), and voluntary product inventories. However, he noted that few of these were originally designed to detect or report on POPs, which limits their scope and effectiveness.
He also critiqued the current labeling practices under the Stockholm Convention. Of the few POPs with labeling requirements, such as HBCD, most labels are lost during the product’s life cycle or are rendered meaningless once the product becomes waste. Digital alternatives, while promising, face challenges of cost and integration.
In conclusion, Peter emphasized that, despite Article 6 obligations, countries are struggling to identify POPs effectively. He warned that without clear definitions, accessible technology, and upstream disclosure systems, enforcement of the Stockholm Convention will remain inconsistent. His message reinforced the call for harmonized, practical, and globally applicable traceability systems.
Kei Ohno Woodall
Kei Ohno Woodall, Senior Programme Management Officer at the Secretariat of the Basel, Rotterdam, and Stockholm Conventions, delivered an informative presentation that highlighted both the complexities and opportunities in advancing chemical transparency, particularly regarding POPs and plastics. Her presentation served as both a technical overview and a thoughtful reflection on the remaining gaps in global efforts to track, regulate, and mitigate the impact of hazardous chemicals throughout product life cycles.
Ohno opened her remarks by underscoring the scale and nuance of the problem. She noted that while progress has been made, the conversation remains dominated by challenges rather than concrete solutions. A critical issue she pointed out is the breakdown in the flow of information along the value chain: even when hazardous chemicals are identified and labeled upstream, this information is often lost or fails for food products could to reach downstream users and regulators responsible for ensuring effective environmental management. Her anecdote about using a consumer-facing app (Yuka) —which evaluates food and personal care products by scanning barcodes—to check for additives in a product served as a powerful metaphor, illustrating how readily available digital tools can empower consumers and offer a model for broader chemical transparency systems.
In the core of her presentation, Ohno guided the audience through the institutional mechanisms embedded in the multilateral environmental agreements (MEAs) such as the Basel, Rotterdam and Stockholm Conventions. She described how these frameworks govern the identification, risk profiling, and potential listing of hazardous chemicals, with special attention to those commonly found in plastics. Ohno highlighted publications and collaborative efforts, including the UNEP report on chemicals in plastics, that have systematically mapped chemicals of concern. She was clear in noting that while some hazardous chemicals are already listed under existing frameworks, many remain outside their scope due to insufficient data, lack of formal proposals, or because they have not been considered to meet the listing criteria. Examples include widely used plastic additives like bisphenol A and various phthalates.
A significant part of her discussion centred on the Stockholm Convention’s POPs Review Committee (POPRC) and its five-step evaluation process, which includes the submission and screening of initial proposals, risk profiling, socio-economic evaluation, and a final decision by the Conference of the Parties (COP). Ohno emphasized the role of scientific rigor and precautionary approach in the decision-making process, citing the recent listing of UV-328—a non-halogenated chemical used in plastics—as a meaningful example of evolving regulatory standards.
She also expanded the conversation beyond the Stockholm Convention by discussing the relevance of the Basel Convention’s plastic waste amendments, which introduced binding requirements for the prior informed consent (PIC) procedure for all plastic waste, except for those that are readily recyclable. Ohno noted that effective implementation of these amendments depends in part on the ability to identify hazardous constituents in plastic waste, among other factors, once again bringing transparency and traceability to the forefront.
Finally, Ohno addressed the overlapping yet complementary roles of other agreements, such as the Minamata Convention on mercury and the Montreal Protocol on ozone-depleting substances. These conventions intersect with the plastics and chemicals agenda through industrial processes, including polyurethane and vinyl chloride monomer production, as well as the use of blowing agents in plastic foam products.
Timo Seppälä
Timo Seppälä, Senior Officer at the Finnish Environment Institute, presented an unvarnished account of how chemical transparency is implemented at the national level, offering a detailed case study on Finland’s implementation of EU regulations related to the Stockholm Convention.
He began by highlighting the various regulatory drivers at play, such as the EU POPs Regulation (2019/1021), which prohibits the use of persistent organic pollutants (POPs) in substances, mixtures, and articles, including imported goods. The regulation also includes a legal requirement for companies to report stockpiles exceeding 50 kilograms of banned substances, including articles containing them, until exemptions expire.
Despite the robustness of this framework, Timo was candid about the challenges Finland has encountered in practice. He noted that although the legal infrastructure exists, compliance and awareness are extremely limited. To date, there have been virtually no stockpile notifications in Finland or across the EU for articles containing POPs. This indicates either a lack of information,a poor understanding of the obligations or limited enforcement.
One of the core problems he identified is the difficulty companies face in knowing whether their products contain POPs. In many cases, firms dealing with spare parts, such as automotive fuel pumps or electronic components, have no means of verifying the chemical content of their stock, particularly when the items were produced outside the European Union. This lack of traceability upstream renders compliance nearly impossible, even for well-intentioned businesses.
Timo provided insights into Finland’s enforcement tools. He explained that companies failing to report stockpiles could theoretically face criminal penalties. However, in practice, enforcement has been minimal. He also highlighted the EU’s RAPEX system for alerting member states to hazardous products, noting that few alerts pertain to POPs—a testament to the difficulty in identifying and reporting them.
Another point of concern was the short timeframe between the expiration of exemptions and the requirement to notify. Many businesses are unaware of when these deadlines occur, and the dynamic nature of supply chains complicates the tracking process.
Timo’s overarching message was one of regulatory ambition tempered by practical constraints. While the EU and its member states have established robust legal frameworks, the lack of product-level chemical traceability makes meaningful enforcement challenging. His remarks reinforced the need for global and interoperable systems that promote chemical transparency upstream, rather than relying on end-users and recyclers to bear the responsibility burden.
Andreas Prevodnik
Andreas Prevodnik, senior chemical policy advisor at the Swedish Society for Nature Conservation, provided a systems-level perspective on how chemical traceability can be operationalized through technology and standardized data systems. His presentation shifted the discussion from policy goals to implementation, focusing on how to embed chemical transparency into product design and information infrastructure.
He began by outlining the three essential conditions for effective traceability:
1. A harmonized approach to disclosing the presence, identity, and hazards of chemicals.
2. The ability to link chemical information to specific items or components through reliable traceability mechanisms.
3. Clear assignment of stakeholder responsibilities—particularly for manufacturers, importers, and regulatory authorities.
Andreas discussed the variety of physical and digital technologies available to support these goals. He examined several types of data carriers, including:
– Hang tags and printed labels
– QR codes and barcodes
– Watermarks and laser etchings
– RFID tags
– Chemical markers and synthetic DNA
He drew attention to the Holy Grail 2.0 project as a proof of concept. In this initiative, watermarks are embedded in plastic products during the moulding process. These marks are machine-readable even on small fragments and enable automated identification of product composition. Andreas argued that similar systems could support traceability, particularly in waste management and recycling contexts.
He emphasized that physical labels are not enough—they are easily lost, degraded, or destroyed during product use and disposal. Therefore, information should also be stored digitally. This is where Digital Product Passports (DPPs) become crucial. A DPP, when linked to a product via a unique identifier (such as a QR code), allows users to access information stored in a centralized database. Such systems would allow recyclers, customs officials, and downstream users to verify chemical content in real time.
He explained that to make these systems effective across supply chains and jurisdictions, data standardization is vital. Without harmonized formats and protocols, systems become fragmented and burdensome for companies. He referenced UNECE’s emerging protocol and the EU’s digital passport initiative as promising steps toward interoperability.
Andreas closed by advocating for legally binding requirements on industry to disclose chemical information using these systems. He stressed that while the technical tools already exist, political will and regulatory alignment are needed to implement them at scale.
Rico Euripidou
Rico Euripidou, from groundWork South Africa, delivered a powerful and deeply human-focused presentation that highlighted the real-world consequences of weak chemical traceability systems—especially in low- and middle-income countries (LMICs).
His remarks centered on the disproportionate exposure of LMIC populations to hazardous chemicals, particularly Persistent Organic Pollutants (POPs) embedded in consumer and industrial products. Rico argued that because many developing countries are net importers of goods, they rely heavily on information about the chemical composition of those products to make safe regulatory and trade decisions. Yet, in the absence of global transparency requirements, they are left in the dark.
Rico illustrated how informal recycling systems dominate waste management in much of the Global South. Waste pickers, often working without protective equipment or regulatory oversight, handle plastics and electronics that contain toxic additives and legacy POPs. Without labels or digital records, these workers and the communities around them are unknowingly exposed to dangerous substances through air, water, and soil contamination.
He made it clear that LMICs generally lack the infrastructure needed to detect or test for hazardous chemicals:
– There are few accredited laboratories.
– Customs officials cannot verify chemical content at ports of entry.
– Governments lack the resources to build national chemical inventories.
This makes LMICs uniquely vulnerable to what he referred to as “toxic dumping”—the flow of contaminated, obsolete, or otherwise hazardous products into low-regulation markets. And because there is no global disclosure mandate, these countries are expected to manage the risks after the damage is done.
Rico emphasized that the solution lies in global action, not fragmented national efforts. A globally harmonized and legally binding chemical traceability system would provide LMICs with the upstream data they need to make informed decisions and prevent exposure before it occurs. He emphasized the importance of incorporating such a system into the Global Plastics Treaty and aligning it with the priorities of environmental justice and public health.
His remarks reminded the audience that behind every policy discussion and regulatory framework are real people—waste pickers, children, communities—whose lives are shaped by the decisions made in international forums like the BRS COPs.
Alexandra Caterbow
Alexandra Caterbow, Co-Director of HEJSupport, concluded the event with a summary and a call to action. Her remarks synthesized the technical, policy, and humanitarian perspectives raised throughout the session.
She began by reiterating the central premise of the event: that chemical transparency and traceability are not only feasible but essential for achieving a toxic-free circular economy. She emphasized that while voluntary programs and regional regulations have laid important groundwork, they are no substitute for a globally harmonized, legally binding framework.
Alexandra called for the integration of mandatory disclosure requirements into the Global Plastics Treaty—specifically referencing Article 3.8bis, which could serve as a foundational clause for future system development. This, she argued, would ensure that traceability is not treated as an afterthought but is embedded from the outset.
She also emphasized the importance of interoperability across initiatives, warning against the proliferation of fragmented systems. To that end, she encouraged coordination between:
– UNEP’s Digital Product Information System
– The UNECE Transparency Protocol
– The EU Digital Product Passport and SCIP database
Her message to policymakers was clear: building separate systems may seem more manageable in the short term, but it will create unnecessary costs and complexity for both regulators and the industry in the long run.
In terms of next steps, Alexandra advocated for a UNEA resolution to initiate the development of a global traceability system for chemicals in products. She noted that such a resolution would provide formal international backing for the ideas discussed at the event and give momentum to cross-sectoral collaboration.
She concluded by calling on delegates, civil society, and industry stakeholders to take action now. With treaty negotiations underway and public awareness of chemical risks growing, she emphasized that this is a critical window of opportunity and urged the global community to move from discussion to implementation.
Watch the recording of the side event
Presentations
Olga Speranskaya (HEJSupport): Global and regional developments on chemical transparency and traceability in products
Peter Dawson, POPs Review Committee, Stockholm Convention: Report on options for identifying persistent organic pollutants in stockpiles, products, and articles in use, as well as in wastes
Kei Ohno Wodall (Senior Programme Management Officer, Secretariat of the BRS Conventions): Approaches and lessons learned from multilateral environmental agreements on chemicals and waste
Andreas Prevodnik (Swedish Society for Nature Conservation, SSNC): Chemical transparency information and its traceability in products and stockpiles, with a focus on POPs and chemicals in plastics
Timo Seppälä (Senior Officer, Finnish Environmental Institute): POPs in articles – views from a focal point
Alexandra Caterbow (HEJSupport): Recommendations
