French Report Highlights Urgent Need to Control Hazardous Substances in Plastic Recycling

Developed under the French government’s COP framework (Jalon 7, Objectif 4), the study warns that the continued presence of legacy substances in recycled plastics poses serious threats to regulatory compliance, public health and environmental safety.

It calls on all stakeholders across the plastics value chain to strengthen their monitoring and risk mitigation strategies.

The 144-page report consolidates the latest knowledge on how substances of concern—including brominated flame retardants, phthalates, PFAS and heavy metals—persist in post-consumer plastic waste.

Despite advancements in EU regulations such as REACH, CLP, POP and the Waste Framework Directive, INERIS highlights persistent gaps in the identification, traceability and control of these additives within recycling processes.

Legacy Chemicals Undermine Circular Economy Goals

One key issue raised is the continued circulation of “legacy chemicals.” These are substances that were legally used in virgin plastic production but are now restricted or banned due to their carcinogenic, endocrine-disrupting or bioaccumulative properties.

According to the report, many of these chemicals can survive conventional recycling methods—whether mechanical, chemical or thermal—and re-enter the supply chain in new products.

The risks are particularly acute in waste streams originating from electrical and electronic equipment (WEEE), end-of-life vehicles, and packaging.

In one analysis cited, more than 66% of recycled plastic flows contained substances of concern, with potential exposure pathways including inhalation, skin contact and even ingestion, particularly through food-contact applications.

Regulatory Gaps and Technical Barriers Persist

Although the EU regulatory landscape has evolved significantly, the report notes that legal and technical obstacles continue to hinder enforcement.

While REACH and POPs legislation set strict rules on the use of hazardous additives, their application in recycling operations remains inconsistent. INERIS calls for improved upstream sorting, clearer criteria for "end-of-waste" status, and more precise characterisation techniques to ensure harmful substances are not inadvertently reintroduced into circulation under the pretext of circularity.

The lack of harmonised thresholds for residual chemicals in recycled plastics further complicates compliance, especially in sensitive applications such as food packaging or automotive interiors.

Health and Safety Hazards Beyond Chronic Exposure

The report also draws attention to acute safety hazards.

Certain additives—particularly those containing halogens—can release toxic emissions or trigger explosions when subjected to heat during recycling.

Case studies of fires in recycling facilities show that such incidents often result in the release of persistent organic pollutants (POPs), posing risks to both human health and the wider environment.

Industry-Wide Response

Urged INERIS concludes that recyclers cannot shoulder this burden alone.

The report calls for a coordinated industry response involving product designers, manufacturers, waste handlers and policymakers.

It recommends designing products with safe end-of-life processing in mind, eliminating legacy additives where possible, investing in advanced sorting and decontamination technologies, and improving transparency through platforms such as the ECHA’s SCIP database.