This week the EU’s much anticipated new chemicals strategy for sustainability was launched. Here representatives from The Natural Step’s chemicals coalition give a summary and share their views on what it means. 

Context

This strategy is one of the milestones for implementing the European Green Deal to create a sustainable, climate neutral circular economy by 2050.  Its a big deal because it provides a long-term vision for reviewing and updating EU chemicals policy for the first time in 20 years. The goal is ”a toxic-free environment, where chemicals are produced and used in a way that maximises their contribution to society including achieving the green and digital transition, while avoiding harm to the planet and to current and future generations”.

The strategy is also a strong signal that Europe continues to take the global lead in tackling the growing impact of chemicals on human health and the environment. As noted in the strategy, Europe already has one of the most comprehensive and protective regulatory frameworks for chemicals. Yet it is clear that more work needs to be done to address the too slow progress substituting hazardous chemicals, to streamline regulation, ensure its enforcement and promote sustainable development. We welcome the strengthened leadership from the EU on chemicals. 

What’s it about?

The EU strategy covers more than 50 actions to better protect citizens and the environment from the harmful effects of chemicals while also promoting innovation and competitiveness of the EU industry. In particular, it emphasises new demands to create chemicals that are ‘sustainable by design’, more life cycle thinking, higher standards and information exchange to ensure safe recycling within the circular economy, attention to greening and digitizing chemical production and securing Europe’s autonomy over critical supply chains and chemicals. Measures to restrict substances of concern in certain product categories – designed to protect consumers and vulnerable groups – will now also include assessment of combination effects of chemical mixtures.

There are other improvements to the EU’s chemical legislation including a simpler “one substance one assessment” process for the risk and hazard assessment of chemicals. This signals a move away from assessing and regulating chemicals substance-by-substance to regulating them by groups. Finally, the strategy emphasizes that the EU wants to play a leading role globally in championing and promoting high standards on chemicals, including not exporting chemicals banned in the EU and ensuring they are not introduced to the common market.

Reflections

A more upstream approach. Generally-speaking, the EU chemicals strategy for sustainability suggests a shift from seeking to control chemicals once they are on the market to a more preventative and upstream approach. This is a positive development, though there will be challenges to ensure that the competitiveness of European industry is secured as the strategy is implemented over time. So far the response from industry has been somewhat positive even while concerns and missed opportunities are also highlighted (CEFIC).

Striking the right balance? The strategy appears to be looking for a balance between designing for sustainability in new products, breaking the ‘take-make-waste’ model by allowing for recycling of waste from ‘linear products’ and encouraging measures to decontaminate materials containing substances now restricted by more recent regulation. While continued dialogue with stakeholders will be needed to find the right balance, we see this as a sign that knowledge domains on the regulation of hazardous substances, circular economy and achieving sustainability goals such as the Paris Climate Agreement and the United Nations Sustainable Development Goals are starting to align.

Accepting the need to do more to tackle chemical pollution. The EU strategy also seems to acknowledge the central issue that despite much progress, chemical pollution is still alarmingly out of control even as the global sale of chemicals is expected to double by 2030. The United Nation’s Global Chemicals Outlook II Report – to which our team contributed – has highlighted this issue clearly:

Large quantities of hazardous chemicals and pollutants continue to leak into the environment, contaminating food chains and accumulating in our bodies, where they do serious damage. Estimates from the European Environment Agency suggest that 62% of the volume of chemicals consumed in Europe in 2016 were hazardous to health. The World Health Organization estimates the burden of disease from selected chemicals at 1.6 million lives in 2016. The lives of many more are negatively impacted.

UN Environment Global Chemicals Outlook 2019

Areas for clarification

While we are positive to the ambitions of the EU strategy, The Natural Step is seeking clarification and suggests that greater attention in needed in a few key areas:

1. Unclear definitions such as a ‘sustainable chemicals’ devoid of context. The strategy refers to the terms like ‘sustainable chemicals’ and ‘sustainable by design’. Our view is that substances themselves can be classified, restricted, prioritized (preferred) and managed in the context of achieving a sustainable society but are neither intrinsically sustainable or un-sustainable on their own. There is bound to be confusion in this area if the differing interpretations of what is ‘sustainable’ are not addressed from a scientific and systems-based perspective. This must also recognise the dynamics of sustainable development as a journey, taking into account the contribution of chemicals to achieving sustainable outcomes throughout their full life cycle. 

2. Chemical management from a systems perspective. As the Earth is a closed system with respect to matter, we believe it is important to foster the mindset and capability to manage ALL chemicals and materials sustainably. While the strategy aims to promote sustainability, it appears to be largely about moving away from today’s known problems (addressing the ‘bad apples’). In our view, substances of concern should be seen as the highest priority but with continued discovery of new chemical impacts and combined effects this should be recognised as a moving target.

We need to take a wider and more preventative view of all chemicals that goes beyond what is currently known or suspected in terms of toxicity and hazardous properties. This means defining the potential for all substances to be sustainably managed under the strictest regimes while also recognising that even ‘non-hazardous’ chemicals can have large impacts on the systems we depend upon. For example, systematically increasing concentrations of ‘non-hazardous’ greenhouse gases are the main driver of climate change.

3. Innovation beyond regulation and compliance. While regulation is a key driver for change, we know it is not enough on its own. We encourage EU policy-makers to continue engaging with corporate sustainability pioneers, responsible investors and other stakeholders to ensure that efforts to go ‘beyond regulation’ are rewarded and incentivised. It is widely acknowledged that industry hates uncertainty but can adapt to higher standards when the trajectory of new regulation is clear. This must be aligned with more progressive, voluntary frameworks to avoid confusion. Therefore we believe effort needs to be invested in ensuring that universally accepted chemical and sustainability indicators are integrated into sustainability tools and disclosure frameworks in mainstream use by industry.

4. The need for a science-based definition of sustainability. As suggested above, this strategy is a chance for policymakers to address regulatory conflicts between chemicals and waste legislation, neither of which were developed with a holistic view of circularity and sustainability in mind. It will be important now to build long-term alignment on how the use of chemicals contributes to the creation of a flourishing and sustainable society. Ultimately, we believe that policymakers need to be guided by a shared and science-based definition of sustainability, the lack of which is one reason why objectives of a non-toxic environment and the circular economy have been seen to be in conflict. We also also note that there will need to be alignment between the EU strategy and the work by UN Environment on ‘Manuals for Sustainable Chemistry‘.

Support from The Natural Step

The Natural Step has been a long-time champion of an integrated approach to chemical management as part of sustainable development. We advocate the use of a science-based definition of socio-ecological sustainability in the form of principles that serve as criteria for evaluating overall progress toward a sustainable society. Because this definition is science-based, it can be applied to any endeavour related to achieving sustainability – including chemical management. Our experience with proactive organisations shows that it provides a pragmatic approach to apply systems thinking to avoid future problems by using sustainability principles as a lens to evaluate the use chemicals and materials.

We invite you to contact any of our representatives to learn more about how to integrate the principles of sustainability into proactive chemical management practices as part of an integrated sustainability strategy.

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