Comments on Interface Between Chemical, Product and Waste Legislation


amfori participated in the European Commission stakeholder consultation addressing the interface between chemical, product and waste legislation. The European Commission’s work on the chemical, product and waste interface is important to amfori members, as it is likely to affect established corporate policies and tools that were put in place to comply with existing EU regulations, most notably REACH.

amfori published a position paper outlining our contribution to the consultation.

The paper:

  • highlights the importance of following a risk-based approach during material recycling. amfori fully supports that all primary and secondary raw materials should be subject to the same rules.
  • cautions that this should not lead to a situation where certain materials must be excluded from recycling due to the presence of a specific substance, which, as such, might not necessarily represent a risk, depending on the stability of its structure in the material matrix.
  • Points out clear advantages in taking stock of existing best practices in the context of reporting on substances of concern in different industries.

Finally, amfori emphasizes the need for promoting a better understanding in sourcing countries of EU chemical policy and REACH in particular and supports an approach that takes into account the complexity and reality of global supply chains.

Read the full position paper.


The consultation builds upon the European Commission's Communication published on 16 January 2018 and seeks feedback on the different options and questions put forward regarding the four main issues described in the Communication and accompanying Staff Working Document.

The main issues were identified as:

1. Insufficient information about substances of concern in products and waste;

2. Presence of substances of concern in recycled materials and in articles made thereof;

3. Difficulties in applying End of Waste criteria and

4. No clear application of EU waste classification methodologies.

amfori would welcome any comments on this consultation, please contact

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June 2017 Position Paper: Addressing the interface between chemical, product and waste legislation

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