The non-governmental organization ChemSec has published a set of five aspects that it sees as important for the European Commission (EC) to include in its upcoming chemical strategy set to be announced this summer (FPF reported) in the context of the European Green Deal (FPF reported). ChemSec writes that the EC “needs to assure that substances of concern are phased out from products and our society in order to protect human health and the environment – as well as to pave the way for a toxic-free circular economy.” The chemical strategy developed by the EC “must include clear commitments, deadlines and deliverables as well as a more ambitious chemicals legislation.” To do this, ChemSec recommends the EC focuses on including the following five aspects:

  • Supporting EU industry frontrunners: This includes developing incentives for companies to phase out chemicals of concern, securing the market for companies producing safer chemicals, and providing derogations to regulatory restrictions only for essential uses defined as being “necessary for health, safety or the functioning of society.”
  • Speeding up the regulatory process and avoiding “paralysis by analysis”: This includes applying the precautionary principle to make decisions even when not all possible data is available, regulating entire groups of substances instead of regulating substance by substance, and providing incentives for companies to provide comprehensive information on substances.
  • Strengthening the balance between generic and specific risk assessment across EU chemicals regulations: This includes increasing the application of a hazard-based approach for regulatory action based on a chemical’s intrinsic properties regardless of where and how it will be used.
  • Ensuring transparency and traceability to achieve a clean circular economy: This includes creating commitments towards full chemical transparency in both supply chains and for consumers and applying equivalent requirements for both recycled and virgin materials. Doing so will avoid the presence of hazardous chemicals in recycled products.
  • Closing existing gaps in EU chemicals regulations: This includes applying the same regulatory requirements to imported products as applied to domestic products, identifying and minimizing exposure to EDCs through hazard-based risk assessments, defining an assessment factor to consider exposure to chemical mixtures, regulating the use of very persistent chemicals, and bolstering enforcement mechanisms in EU member states to ensure regulations are followed.

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ChemSec (May 2020). “5 aspects that the Chemical Strategy must include.”

Chemical Watch (May 7, 2020). “NGOs set targets for new EU chemicals strategy.”