BSEF Position Paper: Circular Economy Action Plan 2020


BSEF, the International Bromine Council, supports the strong EU drive for a more circular economy contributing to a more sustainable and greener future. The recently adopted EU Circular Economy Action Plan[1] as part of the EU’s “Green Deal”, sets out a range of actions and initiatives designed to enhance circularity. However, making the EU economy more “circular” also implies changes to its industrial development and innovation models. Close synergy is therefore needed between the Circular Economy Action Plan and the proposed EU Industrial Strategy.

Bromine-based technologies already contribute to sustainability and circular solutions. Bromine offers solutions to a wide range of environmental, social and economic needs including water treatment, reduction of mercury emissions, fire safety, energy storage and generation, production of pharmaceuticals and enhanced quality rubber for durability and safety.

With respect to brominated flame retardants (BFRs), their use in materials and products contributes to their overall safety (reduced propensity of material for ignition). This not only means a contribution to saving lives, but also products and property, thus preventing waste of resources.  At the end of life, plastics products containing brominated flame retardants can undergo several waste management treatment options depending on the amount and composition of the plastics waste stream as well as on local conditions. BSEF companies are actively working with value chain stakeholders to further enhance circularity of materials by investing in novel end of life technologies (see annex – download).

The chemical industry, with its substantial innovative capacity, and is a key enabler in the development of solutions which can accelerate the transition to a circular economy and contribute to meeting the goals of the European Green Deal, the Paris agreement and the UN 2030 Sustainable Development Goals.

BSEF member companies[2] are members of the European Chemical Industry Council (Cefic) and BSEF itself is a partner organisation of Cefic. It therefore supports the view that guiding principles[3] are needed for the development of an EU Circular Economy including:


  • Developing a sustainable business case in which economic, societal and environmental aspects are balanced, whilst maintaining the competitiveness of the European industry
  • Increasing the share of circular feedstock, through reuse of materials, extension of lifetime using more durable materials, resource recovery and mechanical, dissolution and chemical recycling technologies of waste
  • Building on and driving scientific and technological innovations, to better use resources as well as ensure effective and efficient end of life reuse, recycling or other sustainable end of life solutions
  • Ensuring a life-cycle approach to effectively ensure the reduction of chemical exposure and emissions
  • Taking a collective value chain approach over the lifecycle of materials /products to enhance circularity
  • Recognising and reinforcing a risk-based approach to end of life treatment of materials containing hazardous substances

BSEF, on behalf of the bromine industry, will actively engage in the roll out of the plan and provide input to those elements where it can actively contribute to providing expertise and solutions. Additionally, BSEF member companies will continue innovating and investing in solutions that will help the EU achieving its Circular Economy goals while they also contribute to economic growth and job creation. We look forward to engaging with the Commission, Member States, the European Parliament and other stakeholders in the upcoming discussions. We will also be actively engaged on sector specific and value chain initiatives designed to address end of life issues.

BSEF has carefully reviewed the specific actions and initiatives proposed by the European Commission in its EU Circular Economy Action Plan. The following are its comments and suggestions with respect to the further development of these proposals in the coming years.


Development of a Sustainable Product Policy Framework

BSEF supports greater producer responsibility based on value chains taking responsibility for achieving sustainability and circularity. For instance, its voluntary emission control action programme – VECAP[4] has been instrumental in substantially reducing losses and waste of brominated flame retardants from production and downstream user industrial installations.


Priority Product Groups

BSEF welcomes the Commission proposal for a “Circular Electronics Initiative”. The ubiquity and diversity of electrical and electronic equipment in society has been transformative across many economic sectors as well as in our social and leisure activities. Such equipment plays its part too in managing and facilitating our shift to electrical energy as the main energy driver. Flame retardants and particularly brominated flame retardants have been and will be at the forefront in ensuring that such equipment meets fire safety standards keeping people and property safe from fires.

In terms of circularity, The EU already has several legislative tools in place concerning collection and recycling of electrical and electronic equipment, notably the WEEE Directive[5]. The WEEE CEN Standards[6] greatly aid the safe end of life treatment of WEEE waste. However, they are voluntary. BSEF would support them being made mandatory to harmonise the approaches to WEEE treatment across the EU. Additionally, BSEF would like to see a review of the WEEE Directive requirement for mandatory separation of BFR containing plastics given the continuing decline of legacy POPs BFRs. Currently, all BFRs are penalised due to this requirement.

Finally, BSEF welcomes the Commission proposal to review ‘’EU rules on restrictions of hazardous substances in electrical and electronic equipment… to improve coherence with relevant legislation, including REACH and Ecodesign’’.  Based on recent and direct experience with both instruments mentioned as well as overlap with the EU’s Restriction of Hazardous Substances (RoHS) Directive, we can only endorse any measures.


Enhancing circularity in toxic free environment

BSEF would like to see a risk-based and practical approach to enabling circularity of products and materials. A risk-based approach will enable maximum recycling of materials at the same time ensuring limit values for hazardous substances that are protective for human health and the environment.


Revision of the EU POP Regulation limit values for PBDEs and HBCD

BSEF notes the intention of the Commission to review the annexes in the EU POP Regulation Recast of 2018. Any review of the limit values for low POP concentration limits (LPCL) and related unintended trace contaminants values (UTC) contained in the 2018 Regulation, need to be based on a risk assessment as well as consideration of the technical and economic feasibility for recyclers to meet any lower limit values.

In the medium term, the emergence of new chemical recycling technologies (such as dissolution technologies) will allow for further enhancement of treatment of materials containing legacy substances such as POPs thus contributing further to the circular economy. BSEF members and the associated value chain are already working to demonstrate the application of innovative technologies to address legacy substances and material circularity with assistance from the EU LIFE programme[7].


Revision of the Waste Shipment Regulation

BSEF welcomes the initiation of a review of the EU Waste Shipment regulation[8] as critical to ensuring circularity within a EU context. With respect to electrical and electronic waste, the problem is particularly acute. On the one hand, this waste, which can be “hazardous” given its multiple material and substance composition, is not being treated safely in a number of third countries. On the other hand, these products contain valuable raw materials such as precious metals and indeed critical raw materials, which should be recycled within the EU and reused within an EU manufacturing context. Strengthening rules under the WSR on export prohibitions for certain categories of waste and certain destinations should therefore be actively considered.



[2] BSEF member companies are Albemarle, Lanxess, ICL group and Tosoh

[3] CEFIC views on circular economy 2.0 – Towards a carbon-smart circular future

[4] For more information VECAP visit:

[5] Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and electronic equipment (WEEE)

[6] WEEE CEN Standards – EN 50625 series

[7] EU LIFE Project 16 ENV/NL/000271.

[8] Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste, OJ L 190, 12.7.2006