A background note can be accessed here: OECD on chemical safety risks in recycled plastics
The OECD flags that rising demand for recycled plastics is constrained by the presence of hazardous and poorly tracked chemicals across the plastics lifecycle. How should policymakers reconcile circular economy goals with the need to ensure chemical safety in recycled materials?
The OECD’s analysis brings into focus a structural gap: recycling targets have advanced faster than the systems required to ensure chemical safety in recovered materials. Treating recycling rates as a proxy for sustainability risks embedding unsafe substances back into circulation.
A more grounded policy response rests on three levers. First, traceability must evolve from voluntary certification towards mandatory, enforceable, standardised, value-chain-wide chemical disclosure, especially for persistent legacy additives such as flame retardants and plasticisers. Second, recycled content targets, particularly in sensitive applications like food-grade packaging, need to reflect chemical quality alongside volume, rather than relying on uniform quotas. Third, restrictions on hazardous additives should be applied at the production stage, preventing their accumulation in future waste streams.
This reframes circularity itself. The objective is not simply to increase material recovery, but to ensure that materials circulate with verified chemical integrity and accountability across their lifecycle.
The report highlights that limited information on chemical composition and additives in plastic waste streams undermines trust and scalability of recycled plastics markets. How does this lack of transparency affect the development of efficient secondary materials markets?
Secondary materials markets operate on confidence in both performance and composition. Where chemical information is incomplete or lost across stages of production, use, and recycling, markets face a persistent information asymmetry that constrains scale and value.
In practical terms, this uncertainty suppresses demand and pricing for recycled plastics relative to virgin materials. Buyers factor in verification risks, limiting uptake in high-value applications such as food packaging, medical use, and consumer products for children. The constraint is not always technical feasibility, but the absence of reliable systems to validate chemical safety at scale.
Current certification approaches help, but they remain structurally focused on process traceability rather than enforceable chemical thresholds. Strengthening markets requires internationally harmonised testing protocols, clear safety benchmarks, and interoperable systems such as digital material passports that accompany plastics across borders and use cycles.
With consistent, standardised chemical data, buyers can differentiate quality, unlock higher-value applications, and support price signals that make circular systems economically viable.
OECD analysis emphasises that chemical risks in recycled plastics are often locked in at the design stage, given the diversity of additives used in production. To what extent should policy focus shift upstream toward regulating material design rather than relying on downstream waste management and recycling controls?
The OECD’s emphasis on design-stage decisions highlights where chemical risk is largely determined. Additives introduced during production persist through use and recycling, shaping the safety profile of secondary materials long before waste management systems come into play.
This has direct implications for policy design. Relying predominantly on downstream interventions, such as sorting, treatment, and recycling, places the burden on systems that must manage complexity already embedded in materials. Even advanced technologies face limits when dealing with diverse and poorly documented chemical compositions.
A stronger upstream focus would position eco-design standards at the centre of circular economy policy. This includes restricting substances of concern in new products, requiring substitution pathways for high-risk additives, and embedding disclosure obligations that persist across the product lifecycle. Extended producer responsibility can be expanded to incorporate these design and material choices, not only end-of-life management.
Downstream systems remain necessary to manage existing waste streams. But aligning regulatory effort toward design-stage decisions systematically reduces future risk accumulation and improves the quality and safety of materials entering circular flows.


