Information exchange key to handling SVHCs in circular economy – Dutch report by RIVM states

Challenges outlined in national 2050 plan

Ensuring the sharing of information on substances of concern, including SVHCs, throughout the supply chain is a vital part of realising a truly circular economy, a Dutch report said. The Dutch National Institute for Public Health and the Environment’s (RIVM) ‘Coping with substances of concern in a circular economy’ document, published on 14 May, has identified three challenges the Netherlands faces with its goal for a fully circular economy by 2050.   We were asked to give our views on how to cope with Substances of Concern (SVHC) in a Circular Economy.

WECF’s reflections on Substances of Very High Concern in a Circular Economy

WECF – Women Engage for a Common Future – is committed to achieving a sustainable circular economy and to strengthening the role
of women in that context. An essential condition for the circular economy is that health interests must always be given priority over the economic benefits of recycling. Recent examples have also shown that recycling products that contain harmful ZZS may appear environmentally sound, but still poses unacceptably serious health risks. This has been determined from examples of toys that were made with plastic from electronic waste, containing hazardous substances such as flame retardants that exceeded the maximum value. Another example is the risks of using rubber granules made from old car tyres to produce infill for synthetic turf fields for playing football. Prevention is the keyword when coping with SVHC in the circular economy.

The precautionary principle should certainly apply here if we have not yet achieved a clear understanding of all the effects on human health and the environment. WECF always emphasises that standards, legislation and enforcement should be aimed at preventing exposure of the most sensitive groups, i.e. pregnant women and unborn babies, as well as children in general. There is increasingly clear scientific proof that even minute amounts of SVHC can have a harmful influence on the development of unborn babies and young children. There is also a difference between exposure effects in men and women. Preventive legislation and standards to be imposed if ZZS are potentially allowed into the circular economy must therefore take into account the sensitivity of the most vulnerable groups and the specific gender differences in health effects.

This preventive policy also requires that the government ministries responsible for the environment and for public health have arranged for sufficient expertise to guarantee these priority interests of protecting the environment and public health when drawing up regulations and
standards and measures for their monitoring and enforcement. In principle, we are convinced that public health interests warrant exclusion of SVHC from the circular economy, and that re-use of products containing SVHC can only be permitted if new products cannot in any way expose the population to those substances. This also applies to workers in the re-use sectors

RIVM letter report 2020-0049
Page 67 of 76