The European Commission has published its Chemical Strategy for Sustainability which outlines over 50 actions planned by 2024 for a non-toxic environment. This strategy is setting a new roadmap on chemical policies. It is as ambitious as the strategy that led to the development of REACH 20 years ago.
What does it mean for you?
The 50 actions accompanying the Chemicals Strategy for Sustainability will have an impact on the design of your products, on the sourcing of your raw materials, on the information you will have to provide at customs and on the placement of products on the EU market. The legislative environment will change quickly and this will likely affect the pace of innovation as people work to bring sustainable alternatives to market.
You will have to provide more information on chemicals in your products
The European Commission will introduce extra information requirements on chemicals in products and will track those chemicals:
- Through the SCIP database which went live on the 28 of October: all products placed on the EU market containing substances of very high concern need to be added on this database by the manufacturer or importer of the product.
- By extending REACH Regulation to include harmful polymers, requiring additional information on chemicals such as their environmental footprint and extending the safety assessment of chemicals with the introduction of a mixture assessment factor. The scope of REACH will also be extended with new categories of substances of very high concern (to include endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances).
- By creating product passports that will follow the product during its whole life cycle and contain information on harmful chemicals and their safe usage.
A common open data platform on chemicals will be developed to share, assess and re-use information.
The materials you use will have to be ‘safe and sustainable-by-design’
The European Commission plans to encourage the use of materials designed sustainably and minimise, substitute and eventually phase out harmful chemicals. Harmful chemicals will only be accepted for ‘essential use’.
The Strategy foresees a ‘recycled in the EU’ benchmark that would limit the presence of harmful chemicals in recycled materials by setting the same limits as those for virgin materials. Sectors with the highest circular potential, such as textiles, packaging (including food packaging), furniture, electronics and ICT, construction and buildings, will be prioritised. Authorisation and derogation of restrictions for recycled materials will only be exceptional if justified. The EU will tackle the shortage of recycled materials by boosting innovation that will address the presence of harmful materials in waste streams.
More prevention, enforcement and due diligence
- Prevention: The prevention approach used in chemical legislation will be extended, especially for consumer products. Specific action will be taken to tackle Endocrine Disruptive Chemicals (EDCs) and per- and polyfluoroalkyl substances (PFAS). PFAS will be assessed as a group instead of individually, so they will all be addressed much faster.
- Enforcement: As enforcement remains an issue in chemical legislation, the strategy announces a zero-tolerance approach to non-compliance. With 90% of risk products identified as coming from outside of the EU, the new market surveillance regulation and a reinforced EU customs union will improve enforcement of REACH at EU borders. Cooperation with online market platforms is also part of the strategy.
- Due diligence: Production and use of chemicals will have to be included in the due diligence process currently being developed by the Sustainable Corporate Governance initiative.
How can amfori help you?
More than ever, you need to stay updated on the policies that could have an impact on your sector and adapt adequately. amfori Advocacy is working to shape the chemical policies to facilitate the sustainability of your company. Get in touch with us (firstname.lastname@example.org) to learn how to stay ahead of future legal requirements.
Anticipate future legal requirements by working with your supply chain on sustainable chemical management with amfori BEPI. Through amfori BEPI, you can map your supply chain and identify the environmental hotspots. You can then assign improvement activities and training to your suppliers, monitor their progress and implement a due diligence system.