Eurospace has recently contributed to the European Commission’s public consultation addressing the interface between chemical, product and waste legislation (here). The consultation is part of the Commission’s activities to promote a more Circular Economy in EU.
The European Space Sector is fully committed and has been working since the adoption of the EU chemicals legislation REACH (2006) on a company and sector-level to address the REACH impacts and ensure continued compliance efficiently, in particular with regard to Article 33 communication in the supply chain for Substances of Very High Concern (SVHCs) that may be present in space hardware being very complex objects. With regard to the waste stage, the specifics of space activities, and in particular the operations and decommissioning of space systems outside the EEA (e.g. in outer space) imply a limited scope for the consideration of Circular Economy aspects in the Space Sector. The application of emerging new EU legislation, such as the new public database for SVHCs in articles under Article 9 of Directive (EU) 2018/851 (Waste Framework Directive amendment), and any further provisions to promote the tracking of substances of concern in products and waste should consider this special case. On the specific subject of Article 9 of Directive (EU) 2018/851, Eurospace has therefore sought a legal clarification from the European Commission about its applicability to some areas of Space Sector activity (read here the letter sent to DG ENV).