The European Commission has asked CSS (Chemicals Strategy for Sustainability) roundtable members to contribute to the Union's Strategic Research and Innovation Plan and the SSbD (Safe and Sustainable by Design) framework.
In this context, the 32 members of the CSS Roundtable met during the month of May to develop a report with recommendations. The objective is to prepare the industry for the new obligations under the Commission's final proposal on the SSbD concept expected by the end of the year.
This report contains 10 recommendations and covers several topics such as transparency, cooperation between stakeholders, financing, education and security.
Members say the SSbD concept needs to be expanded globally so as not to "simply shift non-SSbD chemicals to other regions, creating an economic disadvantage for leading companies, particularly in Europe," Joel Tickner, professor at Lowell University and executive director of the Green Chemistry and Commerce Council. It is also a way to "advance science and trade in the EU," according to a representative of Setac (a multi-stakeholder association of toxicologists and environmental chemists).
10 recommendations for the SSbD concept:
- Data for the assessment of the SSbD should be publicly available for reasons of transparency and benchmarking, collected in a harmonized way and shared on an EU-wide basis.
- Ensure that the most inherently hazardous chemicals are not considered SSbD.
- The SSbD framework should stimulate innovation and set higher standards than current regulations.
- Support the further development and validation of New Approach Methodologies (NAMs) that can be applied in the early stages of chemical development, and strengthen synergies for the use and acceptance of NAMs.
- Stimulate cooperation among stakeholders across value chains and all phases of the life cycle - promote forums where stakeholders can share data, information and lessons learned in the design and implementation of SSbD.
- Ensure that funding is clearly oriented towards supporting innovation that serves the general public, societal needs and challenges- replace problematic products/materials at the European, national and international level, in a public/private collaboration.
- Design financial and regulatory incentives to promote pioneers, help bring innovative solutions to market, and promote sustainable development/use of SSbDs based on clear criteria.
- The SSbD approach should not lead to violating minimum safety requirements in the name of sustainability .
- As part of the SSbD concept, both hazard- and risk-based approaches could be included.
- Educate and train the current and next generation of students and workforce in the basic principles of SSbD and the regulatory requirements, to avoid creating new problems for future innovations.
Context: EU Chemical Industry Strategy
On October 14, 2020, the European Commission published a communication as part of its Green Deal Action Plan : “Chemicals Strategy for Sustainability - Towards a Toxics-Free Environment". In it, it outlines its strategy for a green transition and shares its ambition for a zero pollution, neutral, sustainable, circular and inclusive economy.
Thus, the concept of SSbD was developed with the objective of:
- promote a transition to safer and more sustainable chemicals by design. The goal is to significantly reduce the use of substances that are toxic to the environment and to human health
- to stimulate innovation and competitiveness in the European Union
In this context, it will be necessary to integrate in the evaluation of chemical products:
- alternative products that could replace them
- safety considerations based on the life cycle of the product
- sustainability criteria throughout the value chain
- data on the toxicity of chemical substances at all stages of their existence (manufacture, use, recycling, disposal)
Thus, the use of harmful chemical substances in consumer products (cosmetics, detergents, toys, etc.) will be banned according to the EU strategy. Substances considered essential for one of the following criteria are exempted: health, safety or the functioning of society, in case that it is not possible to substitute them.
While this may be seen as a limiting concept for the industry, Martin Brudermüller, president of Cefic and CEO of BASF, says that "it is something that defines the future and confidence.
Through its report “The Safe and Sustainable by Design: a transformative power”, Cefic shares its definition of SSbD as "an iterative process guiding the innovation and market introduction of chemicals, materials, products, processes and services that are safe and deliver environmental, societal and/or economic value through their applications".
The impact for the industry
Chemicals are subject to numerous regulations, including registrationand evaluation of substances (REACH- Registration, Evaluation, Authorisation of Chemicals), labelling and classification (CLP- Classification, Labelling and Packaging), biocides, cosmetics, etc. Thus, restrictions will be applied to these different regulations to comply with the SSbD.
EcoMundo offers support through its SaaS software, REACH Factory, to monitor the compliance of your products throughout their life cycle. Prepare yourself by auditing your chemical portfolios to determine the impact of this strategy on your industry, and by staying up to date on the latest news via EcoMundo's monitoring system. Our experts can assist you in these audits!
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