Stimulating Substitution within a Circular Economy

In the context of the January 2018 ECHA Strategy to promote substitution in favour of safer chemicals through innovation, Eurometaux organised a workshop on 7 November to discuss how to stimulate substitution in the metals sector from a circular economy perspective. The latter is key, since closing the loop through safe reuse or recycling will improve the performance of substances exponentially, significantly lowering the risk of a given material.

For substances deemed to be of Very High Concern (SVHC), however, this is not enough. Eurometaux therefore suggests sustainable substitution only if it is technically and economically feasible from a combined perspective of not only the Circular Economy, but also Chemicals Management and other relevant EU policy objectives, also taking into account societal value and impact.

From a copper perspective, a key ‘live’ issue is that of lead substitution in copper alloys, and Klaus Ockenfeld of Deutsches Kupferinstitut presented a case study on the technical feasibility of lead substitution in copper alloys. While there are solutions to replace some of the technical properties of lead in alloys in a number of applications, there is currently no ‘all-round’ solution, he said. This is despite the fact that the copper industry has long invested heavily in copper alloy research and development, with a view to finding substitution for critical elements. We have reached the current limits of what is technically feasible.

Beyond that, another consideration is the leaded copper alloys currently in use. Thanks to the durability of the materials, they will remain in use—and therefore in the system—for very long periods. This amounts to significant amounts of material we must ensure can still make its way back into EU recycling streams. For copper, around 50 percent of EU demand is met by recycling: the highest number worldwide. If we prevent this, the concept of a circular economy where we keep materials in the loop for resource and economic efficiency falls flat. In other words, it is key to find a balance between recycling and Non-Toxic Environment goals, such as those Dirk Goris of Metallo highlighted in his case study on the impact of substitution by Bismuth on copper recycling and material streams.

In essence, authorisation may well be a well-intentioned chemicals management measure to limit exposure to lead, but we should be careful not to create inadvertent ‘casualties’ in its wake, such as tripping up the broader aspiration of a circular, closed loop economy in the EU.

For copper, there are limited possibilities for the value chain to adapt or respond to the increased presence of ‘contaminating’ elements, and alternative material options are limited. Of those technically and economically feasible alternatives adopted by downstream users, not all necessarily fit with circular economy ambitions. Therefore, it is essential to get a clear signal from regulators that circular economy criteria are a key component of the evaluation when alternatives to SVHCs are assessed. This requires both time and adequate assessment tools.