Risk based management of chemicals and products in a circular economy at a global scale (risk cycle), extended producer responsibility and EU legislation

The problem of cycling of pollutants within global waste recycling streams (risk cycle) can be solved in principle with the aid of REACH regulations. According to the demands of the REACH guidance documents, risk cycle associated emissions would have to be identified during the development of exposure scenarios and to be reduced by risk management measures. This would also apply to chemicals in electronic scrap as they pose health risks to workers at recycling sites with poor working conditions e.g. in Africa and Asia -- regardless if exported illegally. Therefore it is necessary to check whether the substance dossiers of these chemicals, that have or had to be submitted under REACH, have considered such exposure scenarios.Following the extended producer responsibility, there is a need for action. Within the context of European legislation, risk cycle of pollutants can be particularly addressed in the framework of the European chemicals legislation REACH. The legal options are given in principle. However, it is unclear whether the waste life cycle stage (risk cycle) has been and is included sufficiently within substance registration and regulatory review of the registration dossier. Integrating the effects of recycling in developing countries into the REACH regulation is undoubtedly a major challenge. But without doubt avoiding the cycling of pollutants within global waste recycling streams (risk cycle) is a major challenge, too, and in addition one of the core tasks of extended producer responsibility.