CLEPA participates in joint industry position paper regarding the Waste Framework Directive Database

In 2018, an amendment to the waste framework Directive that requires suppliers to notify to ECHA (European Chemical Agency) of the presence of substances of very high concern in articles was approved.


The amendment to Article 9 of the Directive is part of the EU’s circular economy package to develop non-toxic material cycles so that recycled waste can be used as a major and reliable source of raw material, free from hazardous chemicals.


According to the amended Directive, ECHA will establish a new database on the presence of hazardous chemicals in articles by the end of 2019 for waste treatment operators and consumers. The database will comprise information submitted by companies producing, importing or selling articles that contain Candidate List substances. Companies need to submit this information by the end of 2020.


CLEPA believes that the Circular Economy (CE) strategy and its related measures, such as the recent European Commission communication on the interface between chemicals, products and waste, is an important initiative, for both society and industry.


Its ultimate aim is the sustainable use of resources through the entire product lifecycle, which is fully supported by us.


However, CLEPA, together with several other representatives from industry, strongly believe that the database (DB) will not achieve its intended objectives to support the Circular Economy. In addition, the ECHA proposal will not be workable for industry nor enforceable by authorities. Instead, we call for an approach that allows different, flexible and effective CE solutions tailored to the specific circumstances of each industry sector, depending on the complexity and durability of their products.


In this regard, CLEPA, together with industries representing the majority of EU article manufacturers, assemblers, importers and distributors, with a wide variety in size, user base and complexity of processes and products have agreed on a Joint industry position paper. The Joint position asks for an alternative and focused approach, allowing individual sector-specific solutions, which should take into account the complexity and durability of products. Indeed, rather than developing new approaches the paper suggest making use and optimize already existing solutions such as the Waste Catalogue and specific sectoral approaches.



Click on the link below to download the position paper:





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