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NGO view on substitution: Downstream users can put pressure on their suppliers
Public interest and environmental organisations active in the chemicals field play an important role in awareness raising, pressuring policy makers to act in the interest of their supporters and guarding the implementation of the legislation. What do these organisations think of substitution and innovation under REACH and CLP? ECHA Newsletter asked the views of three NGO representatives.
In addition to the Candidate and Authorisation Lists and the criteria for substances of very high concern (SVHC), REACH has made downstream users more aware of chemical safety. They increasingly consider which substances and technologies they choose to use in their products.
"REACH encourages companies to proactively innovate and produce alternative technologies to avoid risks arising from the use of hazardous substances," says Vito Buonsante from environmental NGO ClientEarth.
Anne-Sofie Andersson from the International Chemical Secretariat (ChemSec) and Tatiana Santos from the European Environmental Bureau (EEB) agree. Downstream users need to respond to consumers' questions related to the safety of their products, and therefore have the power to request safer alternatives from their suppliers.
However, substitution is not only the responsibility of the manufacturer. "Innovation for chemicals safety should be a joint responsibility between users and producers," says Ms Andersson. She would like to see innovation as an interactive process between the different actors and points out that this has proven to be more efficient than being stuck with a linear innovation process. The chemicals manufacturing industry should not bear the responsibility for finding new alternatives alone. "However, interactive innovation requires increased transparency from the upstream suppliers," she says.
According to Ms Andersson and Ms Santos, the usefulness of the authorisation process is still unclear.
"Years or even decades may pass from the time when the substance was placed on the Candidate List until it has gone through the authorisation process and its review period," Ms Santos argues.
Ms Andersson worries that the resources invested in applying for authorisation might be taken away from innovating for safer alternatives.
Whereas REACH has its Candidate and Authorisation Lists, the CLP Regulation offers an easy way to evaluate and compare the hazardousness of substances. "Classification is a clear signal of the hazards posed by a substance and it may trigger efforts within the supply chain to replace the substance," Ms Andersson explains.
"Classification also has an important role in occupational legislation which forbids the use of carcinogenic and mutagenic substances in the workplace if substitution is technically feasible," Ms Santos continues.
Benefits for society and economic advantages for business
The three NGO representatives agree that safer products will become a competitive advantage for companies in the future.
As citizens are becoming more and more aware of the hazardous chemicals, they will reward manufacturers who are able to give them safer and more sustainable alternatives. "Companies need to take the critical need for research and innovation in the development of cleaner, less hazardous or damaging technologies seriously," Vito Buonsante says.
In addition to benefits for society and wellbeing, safer products will bring economic advantages for innovative companies. Anne-Sofie Andersson argues that – on the contrary to some industry claims – REACH does not stifle innovation.
"Just last week, two large downstream users told me that the American and Japanese companies fear that REACH will make EU-based companies so innovative that they will leave their competitors behind".
In the future, she hopes that companies could also make use of the non-hazardousness of their products in their marketing.
Developing tools and spreading information
NGOs promote substitution by spreading information, raising awareness and by developing tools that help companies to find safer alternatives to those currently in use.
ChemSec is involved in developing the Substitution Support Portal (SUBSPORT) that can be used as a first entry point by those interested in substitution.
Another important project for ChemSec is the SIN List, which identifies substances that fulfil the criteria for SVHCs. This list is being expanded and a new, more user-friendly version will be launched later this year. "Our SIN List is a useful tool for companies who would like to anticipate which substances may need to be substituted in the future," Ms Andersson highlights. Her organisation is also currently developing a tool for small textile producers. "The aim is to make it easier for the textile industry to start working with chemical issues and find their way forward in a concrete way," she says.
Informed citizens can put pressure on chemicals companies. Both Mr Buonsante and Ms Santos emphasise the importance of raising awareness and educating people.
"ClientEarth believes in the power of information. ECHA is already taking important steps towards providing better information to consumers about the chemicals they are exposed to and the companies putting them on the market by improving its chemicals database," Mr Buonsante says.
The EEB is active in sending proposals for promoting substitution to ECHA. It also supports and promotes SUBSPORT.
"We also find it important to give visibility to all public consultations on alternatives and encourage third parties to submit relevant information," she says.
| Anne-Sofie Andersson. |
| Vito Buonsante. |
Image: Vito Buonsante.
| Tatiana Santos. |
Did you know?
Anne-Sofie Andersson is the Director of The International Chemical Secretariat, ChemSec. ChemSec is a non-profit organisation founded in 2002 by four environmental organisations. Their aim is to make the world free from harmful chemicals.
Vito Buonsante is a Law and Policy Advisor on Health and Environment at ClientEarth. ClientEarth was founded in 2006 and is an organisation of activist lawyers with the aim of bringing together law, science and policy to create practical solutions to key environmental challenges.
Tatiana Santos is a Senior Policy Officer on chemicals and nanotechnology at the European Environmental Bureau. The EEB was created in 1974 and is now Europe's largest federation of environmental organisations. EEB's goal is a healthy environment and rich biodiversity for all of Europe.
European Environmental Bureau
Interviews by Päivi Jokiniemi
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