Material Compliance 2022

NovaLoop Series Part 2: New Dynamics in “Product-related Material Compliance” 2022!

The path to a circular economy is hard to imagine without a recast of product-related material requirements. For the European “Green Deal” goal of achieving climate neutrality by 2050, which is as ambitious as it is necessary, the measures envisaged in the circular economy action plan to transform our “take-make-use-dispose” behavior into a circular economy principle are indispensable prerequisites.

In addition to promoting the longevity and reparability of products (read more about these current developments in Part 1 of our series), the material composition of products is also an important aspect that contributes to closing the loop.

Increase the use of recycled materials!

This year, measures to increase the percentage of secondary raw materials are to be expected on both ends of the spectrum: in securing clean material cycles and in the demand for secondary raw materials.

Accordingly, the adoption of the recast of the Packaging Directive by the Commission, scheduled for the first quarter of 2022, is expected to include concrete requirements for improving packaging design to promote reuse and recycling, as well as for increasing the proportion of recycled materials in packaging.

With France taking over the Council Presidency, it is also expected that the legislative process around the Battery Regulation will also pick up speed again – the latest version of which also provides for mandatory recycled content for certain types of batteries.

Reducing the proportion of hazardous chemicals in products

In order to be able to secure safe recycled content and at the same time increase confidence in such raw materials, authorizations and exemptions from restrictions on recyclates under the REACH Regulation are to be granted only in justified exceptional cases. The Chemicals Strategy for Sustainability already addressed the goal of non-toxic material cycles, which can be supported with amendments to the REACH Regulation. In the current public consultation, feedback on the upcoming revision of the REACH Regulation under the Green Deal can still be submitted until April 15, 2022.

In addition, as part of the Sustainable Products Initiative, information requirements for traceability of substances of concern along the entire product life cycle are also to be introduced – these in turn presuppose a corresponding risk assessment of chemicals, taking into account the entire life cycle of substances, materials and products. We eagerly await corresponding initiatives during the course of the year

Impact: Material, information and labeling requirements

The planned requirements thus extend through all phases of products’ lives, starting with product design, continuing to safety during the use phase and on to recyclability. Hence, changes can be expected, from the Eco-design Directive to chemicals legislation and waste regulations. The central core element and immediate obligation for affected market participants is often an information requirement – be it through appropriate labeling of components and products or within the scope of supply chain communication.

NovaLoop GmbH supports manufacturers in all questions concerning material compliance and environment-related product labeling. We are looking forward to supporting you in 2022 – please contact us!