In a circular economy, long-lived products are recycled and reused. This is advantageous for the environment but also a challenge for consumer safety. Chemicals of concern included by accident or by design in products could become caught in the circle. Combined exposure is possible, and increased recycling and reuse of long-lived products also mean that it can take decades to eliminate legacy substances. Research suggests, for example, that even after a complete ban on the use of bisphenol A in paper receipts, it will remain in recycled paper for up to 30 years. In addition, unforeseeable uses may pose additional risks and a growing share of consumer goods on the EU market is imported from manufacturers in third countries who do not necessarily comply with EU safety standards.

The current EU chemicals laws are no seen as a good basis for a circular economy. Critics warn that the choices we make today have a direct impact on the future health of consumers across Europe. New, stringent controls are needed. Certain products must not be recycled. It is important to not only make sure that the first, intended use of a chemical is safe but also possible subsequent uses. If there is uncertainty or ambition, safer alternatives need to be looked for. Clear and readily accessible information about chemicals of concern in consumer products is required. The industry needs incentives to phase out the use of chemicals of concern.

In summary, the main challenge of a circular economy is neither a technological challenge nor a financial problem but a problem of governance. Keeping material cycles clean is essential for the circular economy. Price, material performance, and trust in the safety of the materials influence the decisions of the consumers and thereby the success of a circular economy.

• Products and precaution in a circular economy,
  Pelle Moos,
  ChemicalWatch 2017.