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Päivi Jokiniemi and Paul Trouth
Article related to: REACH
Promoting substitution to safer chemicals through innovation
Substituting hazardous substances with safer alternatives, contributes to a non-toxic environment, a circular economy and promotes innovation, as well as sustainable production and consumption. ECHA’s new substitution strategy aims to support companies to replace substances of concern with safer substances and technologies.
Moving away from chemicals of concern
REACH, CLP and the Biocidal Products regulations are designed to put pressure on and provide incentives for industry to try to replace hazardous substances with less harmful ones. By implementing these regulations successfully, ECHA directly and indirectly supports substitution.
ECHA’s new strategy aims to boost the substitution of chemicals of concern throughout the EU in different ways. It aims to improve access to ECHA data and increase the capacity of Member States and stakeholders to carry out analyses of alternatives by offering support for innovation and by providing opportunities for networking.
Successful substitution is underpinned by research and development (R&D). So, the strategy looks at ways to help companies innovate and invest in R&D. Since the strategy is linked to current EU priorities on a circular economy, a non-toxic environment and sustainable production and use of chemicals, it calls for coordinated, EU-wide actions that take into account the life cycle of products.
A business opportunity
A stronger foundation for substituting chemicals of concern in the EU is needed. This calls for a change in mindset where substitution is seen as a business opportunity that brings benefits to human health and the environment, rather than as a response to regulatory action.
In this respect, it is an essential building block for reaching the United Nation's 2020 and 2030 sustainable development goals. This mindset change should take place throughout the supply chain, involving retailers and end users of the products, but it should also take place within governments and agencies, too.
Substitution as part of a business model
While the EU chemicals legislation puts regulatory pressure on industry to substitute hazardous substances with safer alternatives – including substances, technologies or organisational measures – it also provides incentives for companies to do so.
To understand the viability of their chemicals portfolios, companies must know the properties and uses of their substances. This knowledge allows them to integrate substitution as an essential part of their business models. By staying at the forefront of the latest technological advances and developments, European businesses can be more competitive. Furthermore, with retailers and consumers increasingly demanding safer products, sustainable chemistry is also progressively becoming a vital element of business planning for investors.
This is where ECHA’s substitution strategy comes in – by supporting stakeholders to move in this direction through four actions areas.
Building up capacity in the supply chain
The first action area is capacity building. There are a number of challenges to substitution, including achieving performance and cost requirements, understanding available options, and evaluating them.
As such, successful supply chain collaboration for these challenges is essential and requires increased skills and knowledge on how to substitute in different parts of the whole chain. There is an imbalance in knowledge at different levels of the supply chain. While substance-level knowhow is greater among upstream manufacturers, downstream users are more likely to have information about different technological possibilities for innovation and substituting hazardous chemicals.
To address this, ECHA plans to collaborate with Member State and EU-level authorities, industry associations and NGOs to organise collaborative workshops on specific substitution challenges that companies face.
The workshops aim to help improve the capacity of companies and authorities concerning analysis of alternatives, innovation and substitution. They will also be an opportunity for various actors to discuss substitution issues specific to their supply chain. The ambition is to understand the needs and make progress in identifying and adopting safer alternatives. The workshops can be held at national level in the local language or at EU level, depending on the need.
ECHA will develop a standard package of methods and content, which can then be used as a basis for organising different workshops.
Getting access to funding and technical support
The second action area concerns access to funding and technical support. While there is some funding available for sustainable chemistry projects at EU and Member State levels, specific funding for substituting hazardous chemicals is scarce.
On top of this, even though research and technical institutions, and suppliers of alternatives often have the knowledge to provide technical support, this is rarely known to those companies facing substitution issues.
Acknowledging this, ECHA will work closely with the European Commission, Member States and stakeholders to map the current funding mechanisms and institutions and make this information available to facilitate R&D activities for substitution purposes. Recognising that ECHA does not provide any funding, the Agency will consider ways of nudging European funding institutions to pay attention to chemicals being used in new innovations (so that these are preferably of no or low hazard) when considering funding applications.
Better use of REACH and CLP data
Sustainable substitution requires a proper understanding of the hazards and risks associated with the substances being substituted. To avoid regrettable substitution, the hazards and risks of alternatives also need to be known. For this, the third action area relates to making better use of REACH and CLP data.
Over the years, ECHA has worked to improve access to its databases. For instance, information from the registration dossiers and classification and labelling notifications is publicly available and directly accessible from ECHA’s website.
This serves stakeholders looking to make well-informed decisions about the substances they manufacture and use.
As part of the strategy, ECHA will see how to improve access to data relevant for substitution purposes.
For registration data, it may be possible to enhance the search functionality by including uses as well as sectors of use. However, the use descriptions in the registration dossiers are currently rather general, so ECHA would need to see how registrants could provide complementary information in their dossiers that would be useful for downstream users assessing potential alternatives.
For data in applications for authorisation and restrictions, information on the analysis of alternatives from the dossiers, as well as key information derived from the public consultations, could also be searchable on ECHA’s website.
ECHA will also discuss with Member States and stakeholders to see what additional data would be useful for them and how existing information could be communicated in a more helpful manner.
Multi-stakeholder substitution networks
The fourth and final action area relates to networking to routinely and effectively connect and collaborate on substitution challenges and opportunities. Creating a network for innovation and substitution could help to advance informed substitution. The Network of REACH Socio-economic Analysis and Analysis of Alternatives practitioners (NeRSAP) has been created by ECHA and industry stakeholders to make such connections. However, more networking is called for.
Networks can be authority-centred, sector-specific or supply chain-specific. They can also be multi-stakeholder networks, consisting of different sectors, different actors in the supply chain as well as different authorities at Member State and EU level.
At ECHA’s substitution workshop on 9 to 10 October 2017, the participants considered that a new multi-stakeholder network supporting innovation and substitution would be the best way to progress in the EU. The network would include ECHA, the Commission, Member State competent authorities, industry organisations, NGOs, research organisations, academia, consumer associations and certain individual companies and would inform and exchange information on various substitution-related activities.
Several channels will be used for this purpose. ECHA’s web pages on substitution will be progressively expanded with additional case studies and material from the supply chain workshops, a series of webinars on substance-specific issues and training on analysis of alternatives, as well as news exchange on social media with a new LinkedIn group.
Success relies on all parties
ECHA cannot promote substitution alone. All actors need to chip in. The substitution strategy can only succeed if all concerned parties get involved. Being proactive, contributing, and having open and solution-oriented exchanges between stakeholders are the key to meaningfully moving away from the use of chemicals of concern.
LinkedIn group: Substitution to Safer Chemicals - European Information Sharing Network
We have formed a LinkedIn group to communicate on substitution-related matters. The group is open to everybody, but to access it, you will need to send a request to us through the LinkedIn feature “request for joining the group”. The group aims to be a collaborative space where you can discuss and share information related to substitution in an easy and interactive way. While we will facilitate the group and post news, the goal is for members of the group to become actively involved and exchange news by themselves.
Swedish substitution centre
Within the work of developing and submitting proposals on how to achieve a non-toxic environment, the Swedish Chemicals Agency (KEMI) proposed to set up a centre that would bring benefits for individual companies as well as society. “We identified that REACH and other chemicals legislation provides the conditions that are necessary to reach a non-toxic environment, but that these measures are not enough,” says Ms Åsa Thors, from the EU Coordination Unit at KEMI.
Text by Paul Trouth
Published on: 15 February 2018
Top image: © Zsolnai Gergely/Fotolia
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Biocidal Products Committee:
26 February-1 March
Committee for Risk Assessment:
Committee for Socio-Economic
18-22 March (tentative)
Management Board meeting:
Member State Committee:
13-17 May (tentative)