Zero Waste Europe has called on the EU to integrate toxic-chemical controls into its upcoming Circular Economy Act (CEA), warning that without binding traceability and transparency rules, the bloc risks a public health crisis from harmful substances in packaging and other products. The recommendation targets PFAS, bisphenols, and phthalates commonly found in food packaging, plastics, and coatings, signaling tighter compliance requirements for chemical suppliers and importers serving the EU market.
Regulatory push for chemical traceability
The report, "Building a healthy circular economy: Integrating chemicals, products and waste under the Circular Economy Act," argues that the CEA must align with the EU's Chemicals Strategy for Sustainability. It calls for binding traceability requirements along the value chain, with substances of very high concern clearly defined in the EU's Digital Product Passport (DPP). Zero Waste Europe emphasizes that documentation for chemicals in packaging is "nearly nonexistent," making testing the only reliable way to verify safety.
Challenges in supply-chain transparency
Dorota Napierska, toxic-free circular-economy policy officer at Zero Waste Europe, notes that packaging traceability is hampered by access to information, even through formal systems such as obligatory declarations of compliance. "While the information requirements include the identification of the materials and substances, information is rarely shared due to 'confidentiality' issues declared by the chemical and materials manufacturers," she says. This creates an excessive burden on small and medium-sized enterprises (SMEs), distributors, and recyclers.
Upstream engagement and digital tools
The report advocates that upstream stakeholders must ensure products are safe for human health and designed for recycling. Napierska argues that digital tools for traceability add value by helping suppliers meet legal requirements, prove compliance, and support high-quality recycling operations. "We believe that if upstream stakeholders are properly engaged, and the system responsible for the operational DPP is well designed and user-friendly, SMEs and recyclers will not be overburdened," she adds.
Ecomodulation fees as an incentive
Zero Waste Europe recommends introducing ecomodulation fees into the European EPR system to incentivize the use of safe chemicals and encourage toxic-free product design. "Ecomodulation isn't really about penalties, but rather about creating incentives for better design, as well as making producers economically responsible for the pollution and treatments of their products, including hazardous chemicals," Napierska explains. She adds that material substitution is often possible when harmful chemicals are deemed non-essential.
What buyers should watch
Chemical importers and distributors should monitor the EU CEA's public consultation, which is expected to lead to a formal proposal in 2026. The push for binding traceability and DPP requirements will likely increase compliance costs for suppliers of packaging chemicals, especially PFAS, bisphenols, and phthalates. Early adoption of transparent documentation and digital traceability tools may offer a competitive advantage as the EU tightens controls on hazardous substances in the circular economy.
Source: Read the original report | Published: February 04, 2026