ARTICLE11 March 2022

Substances of Concern that hamper recycling

“Substances of Concern” has different meanings in different policy initiatives and legislation. This creates a lack of clarity and risks causing confusion. 

Photo: Ernst Henry Photography AB/Scantech Strategy Advisors

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: Substances of Concern in Articles. At present, the term has different meanings in different policy initiatives and legislation. This creates a lack of clarity and risks causing confusion.

The Confederation of Swedish Enterprise focuses on the definition used in the Chemicals Strategy, described in the Chemical Strategy, where SoCs are described as follows: “These include, in the context of this strategy and related actions, primarily those related to circular economy, substances having a chronic effect for human health or the environment (Candidate list in REACH and Annex VI to the CLP Regulation) but also those which hamper recycling for safe and high quality secondary raw materials.” The term thus includes substances defined according to REACH and CLP, as well as substances that can hamper recycling. What is meant by the term ”hamper recycling” is not further defined.

 CEAP includes two measures that refer to SoC: “Harmonized information systems for the presence of substances of concern” and “Methodologies to track and minimize the presence of substances of concern in recycled materials and articles made thereof”. Depending on how the term SoC is defined in this context and which substances are considered to be SoC, these measures may be highly significant for the recycling of materials and products in the future.

Swedish Enterprise has drafted this 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 also believes that it is important that the definition of SoC is uniform and clear in different EU initiatives.

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Subscribe to our Swedish newsletter
Contact our EU Office

Address

Rue du Luxembourg 3
BE-1000 Bruxelles
Subscribe to our Swedish newsletter
Contact our EU Office

Address

Rue du Luxembourg 3
BE-1000 Bruxelles
Subscribe to our Swedish newsletter
Publisher and editor-in-chief Anna Dalqvist