The European Commission will propose ambitious new legislation targeting recycling with a greater emphasis on product design, the new Environment Director General Karl Falkenberg revealed in January this year. If passed, the new rules are anticipated to come into force by the end of 2015. Product developers and manufacturers will need to take note.
The proposal is based on circular economy principles, which depart from the traditional linear ‘take, make, dispose’ model, and is instead restorative by intention and eradicates waste through careful design.
The original circular economy package, which was abandoned at the end of last year in favour of the current, more ambitious,proposal, included traditional end-of-life requirements such as a 70% recycling or reuse target for municipal waste by 2030 and a ban of recyclable materials such as plastics, metals and biodegradable waste going to landfill by 2025.
If new measures on product design are introduced, businesses involved in product development and manufacture are likely to be subject to more onerous compliance requirements, for example, reducing or eliminating the use of substances or materials that hamper recycling, or compelled to produce higher quality technical components designed to be circulated rather than discarded.
The proposals illustrate the increasing focus on product stewardship within environmental law and may have repercussions for all elements of the supply chain.
Burges Salmon’s product stewardship and chemicals regulation team advises national and international clients on all aspects of product compliance. For further information please contact Michael Barlow, William Wilson or your usual Burges Salmon contact.