It seems like every day another country, non-governmental organizations (NGO) or customer is asking you to provide evidence of compliance for another chemical regulation — and this trend shows no signs of stopping. In October 2020, the European Commission released its Chemical Strategy for Sustainability, in line with the objectives of the EU Green Deal that will introduce more chemical regulations and expand the scope of what is already in place. This strategy supports the EU’s vision and goal to be a “sustainable climate neutral and circular economy by 2050.”
This circular economy will be strengthened by a multitude of actions, including creating sustainable-by-design criteria across industries; promoting toxic-free material cycles and clean recycling; and increasing protections for the environment, consumers and professional workers.
These expected chemical regulations are evidence of a trend: the more consumers, NGOs and governments learn about the impact of chemicals on our planet, the more chemical regulations will continue to grow exponentially.
With more chemical regulations, it is vital that you understand the chemistry of your products. Just complying with REACH and RoHS isn’t enough to keep your products on the market. You need a full understanding of your products’ chemistry to comply with a variety of new regulations.
One of the priorities for the EU Green Deal strategy is to work with industries to make products and processes “sustainable-by-design.” By eliminating the use of harmful chemicals in products, the chances for recycling and reuse greatly increase. The EU wants the sustainable-by-design criteria to reach across all industries, especially in chemical and emerging green technologies.
However, the criteria for making products and processes sustainable-by-design are yet to be determined. Once defined, tools, education and metric functions for the initiative will be generated to help guide businesses into making sustainable products.
Prioritizing Toxic-Free Materials
The EU circular economy is already strongly supported by REACH and the mandatory Substances of Concern in Products (SCIP) reporting requirements for articles that contain Substances of Very High Concern (SVHC) greater than 0.1% by weight. With the implementation of the EU Green Deal strategy, these requirements will become even stronger.
The minimization of hazardous substances in products will be achieved by reviewing the necessity of Authorized Uses and incorporating broad risk-based categories instead of the individual assessments of singular chemicals.
This is already happening with the most recent PFAS regulation. Instead of having substance restrictions against specific PFAS, there is now a general ban of all cases. The goal is for substances of concern to be minimized and substituted out of the supply chain, particularly in consumer products.
Environmental and Consumer Protections
Future chemical regulations also look to include additional hazards and scope aimed at protecting the environment, consumers and professional workers even further.
These additional regulations include restrictions on endocrine disruptors in consumer products; strengthening professional workers’ protections to mimic consumer protections; and further restrictions on substances that have environmental toxicity, persistency, mobility and bioaccumulation.
Regulations surrounding these hazards will fall under the “group approach,” meaning all substances that meet the criteria or definition will be under scope and will require a high level of effort to get an approved Authorized Use.
Be Prepared for New Chemical Regulations
Regulations in the EU are just getting underway as governments take actions toward greater environmental and consumer protections. We are seeing more chemical restrictions every year. Having a full understanding of your products’ chemistry will be essential to meeting new regulations.
If you have not already begun to understand your products’ chemistry, you are behind the competition but not out of the game. Start assessing your products for hazardous materials now. The sooner you know, the sooner you can reach the sustainability that will be required.
Contact Tetra Tech for support today at [email protected]. We can help you survey your supply chain, understand your products’ chemicals and advise you on compliance reporting. We also offer training for a variety of compliance reporting software, from IMDS and CDX to the new SCIP database.