At present, the concept of Substances of Concern (SoC) has different meanings in different policy
initiatives and legislation. This creates a lack of clarity and risks causing confusion.
The concept of Substances of Concern (SoC) is found in several current EU initiatives, such as the Circular Economy Action Plan (CEAP), the Chemicals Strategy, Sustainable finance, and in the ECHA SCIP database. Swedish Enterprise has drafted a position paper to present its view on what the part of the concept of SoC that is linked to recycling should mean and how the process for identifying SoC that hamper recycling should work.
Swedish Enterprise believes that it is important that the definition of SoC is uniform and clear in different EU initiatives and has the following key message regarding the management of SoCs that hamper recycling.
1. The definition of SoC should be developed and clarified
It is necessary to develop a clear definition of what is meant by SoCs that hamper recycling. SoC that hamper recycling should have the following meaning: substances that technically hamper or complicate recycling in the recycling process or gives the recycled material for the purpose wrong orsubstandard quality
.
2. The process for assessing SoC needs a clear demarcation and transparency
A transparent process must be set up to identify SoCs that hamper recycling and it must involve business, which have the technical know-how necessary in design and recycling phases. It is crucial that this process leads to equal assessments and competition on equal terms in the internal market. If this is not the case, it can impede efficient circular flows within the EU.
3. Material and product-specific frameworks need to be developed to identify SoC
The frameworks must enable adaptations for different materials, products and applications. They must also be able to adapt to continuous technological development in the recycling sector to reduce
the risk of unnecessarily limiting material recycling.
In the attached position paper, Swedish Enterprise also has a few suggestions on what should be considered in efforts to define SoCs that hamper recycling for various materials and products.
EURecycling