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The new Chemicals Strategy for Sustainability (CSS) was published on the 14^th of October 2020 with the aim to boost innovation for safe and sustainable chemicals and increase protection of human health and the environment against hazardous chemicals.  

The CSS is part of the European Green Deal (EU’s new growth strategy), which targets a sustainable climate neutral and circular economy by 2050. Chemicals have a key role related to low-carbon, zero pollution and energy- and resource-efficient technologies, materials and products.

CCS Key Drivers

One of the main drivers behind this new strategy is the expected increase in chemical production (production of chemicals is expected to double by 2030) and the ‘unknown territory of chemicals risks’ as presented in the below figure from CSS paper. Therefore, authorities are aiming to acquire more information on the intrinsic properties of many chemicals, especially including polymers (which are not subject to REACH registration) and chemicals manufactured in low amounts. Therefore, a proposal will be prepared to extend the duty of registration under REACH to certain polymers of concern.

Photo source: Chemicals Strategy for Sustainability document

The CSS also points out the need of gathering other information requirements under REACH related to the environmental footprint of chemicals (e.g. emissions and greenhouse gases) and to enable identification of all carcinogenic substances manufactured in or imported into the EU (at any volumes).

Safe and sustainable by design:

The first concept to look at refers to the so-called safe and sustainable-by-design. This concept is tentatively defined in the CSS as ‘a pre-market approach to chemicals that focuses on providing a function (or service), while avoiding volumes and chemical properties that may be harmful to human health or the environment, in particular groups of chemicals likely to be (eco) toxic, persistent, bio-accumulative or mobile’. The definition is still tentative as Commissions’ mission is to develop the criteria based on the timeline in 2022.

The aim of safe and sustainable-by-design should minimize environmental footprint of chemicals.

Circular Economy and CSS

In relation to circular economy, Commission would like to make ‘recycled in EU’ a benchmark worldwide. The concept is part of the circular economy action plan published in March 2020 which underlines the required actions on product design, quality and safety of secondary raw materials and enhancing of their markets. At the same time, the new CSS highlights the importance of ensuring that substances of concern in products and recycled materials are minimised’ and enhances the need for a toxic-free material cycles and clean recycling. Therefore, the future actions for Commission in this regard will be focused as an example on:  ECHA’s SCIP database, REACH review, development of product passports and creating a Sustainable Product Policy Initiative (indicative timeline 2021-2022). Sectors underlined with the highest potential for circularity are textiles, packaging, furniture, electronics and ICT, construction and buildings.

As part of EU’s industry green transition, the concept of Chemicals as a service have been introduced. This concept is described as ‘chemicals leasing but also the leasing of services such as logistics, development of specific chemical processes and applications, and waste management’. To reach this aim, innovating in industrial production is fundamental and will require the development of many new  digital technology solutions related to for example: internet of things, big data, artificial intelligence, automation, smart sensors and robotics.

Additionally, another interesting concept introduced in the CSS is related to the criteria for ‘essential use’ which aims to define that only an essential use would be the reason of using most harmful chemicals. The concept is considered especially for endocrine disrupting chemicals (EDCs) which will be banned from consumer products “as soon as they are identified” and also to the use of PFAS which will be phased out in the EU, unless the use is proven to be essential for society. Commission’s timeline to develop such criteria is between 2021 and 2022.

Furthermore, Commission is targeting more simpler and transparent assessment processes and thus the new concept for regulating chemicals by groups is ‘one substance, one assessment’ where the grouping procedures are structural to have functional similarities of substances. The Commission will use a single ‘Public Activities Coordination Tool’ to provide an up-to-date overview of all planned and ongoing initiatives on chemicals by authorities across legislation.

The above approach promotes open data platform on chemicals where the data will be available i.e. in format of IUCLID and IPCHEM. The platform would be part of the European Green Deal data space announced under the EU data strategy.  This relates to simplifying and consolidating the legal framework as the current authorisation and restriction processes will be reformed in terms of shortcomings identified during the REACH review (2018).

Additionally and to serve the aim under the new CSS, actions will be related to strengthen the principles of ‘no data, no market’ and the ‘polluter-pays’ under REACH, in particular by requiring compliance of all registration dossiers and revoking where necessary the registration numbers in case of non-compliance.

How all these changes will be implemented?

The new circular economy action plan includes the key actions which Commission will take in forthcoming years. Actions include: i) establishing of an expert working group and other coordination mechanisms, ii) introducing new criteria and funding and finance support and iii) implementing new EU legislations.

More information on the New Chemicals Strategy for Sustainability can be found HERE.