In response to a public consultation on the interface between chemical, product and waste legislation, Ecopreneur has urged to EU to prevent substances of very high concern (SVHC) from being used in products on the EU market. The sooner companies stop using them, the sooner we can create a circular economy, which consists of clean circles. And the sooner companies using secondary raw materials, or converting waste into secondary raw materials, are informed about the presence of SVHC in the input they receive, they can take measures to avoid them in the secondary raw materials used as input for products entering the EU market.
The list of SVHCs should be reconsidered. All substances of concern should be tracked by a set date. The focus should be on product requirements. The rules for primary materials may be derogated for secondary materials only under strict conditions. EU wide harmonisation of end-of-waste provisions is preferable. Waste should be classified taking into account the bioavailability of substances it contains.
Moreover, to ensure a level playing field, Ecopreneur urges increased market surveillance of imported goods including random, unannounced checks on the actual presence of SHVCs in imported goods, in combination with high fines for their presence above legal limits. The fine revenues by each agency should be added to their budget for market surveillance. The same principle should be applied to market surveillance of all environmental regulations in all member states.