eu chemicals legislation after 2019… eu chemicals industry view · 2019-09-05 · our vision for...
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EU Chemicals legislation after 2019…
EU Chemicals Industry View
Mariana Barros, REACH Manager Product Stewardship – Cefic
REACH Conference 2019, Bratislava05 September 2019
Future of the EU chemicals policy – what has been reported
2nd REACH Review published in March 2019.
In the end of June 2019 the future of the EU chemicals policygot a lot of attention:
• EU report on the findings of the Fitness Check of the mostrelevant chemicals legislation (excluding REACH);
• Environment Council conclusions on chemicals.
Report of the high-level Conference, held on June, on “EUChemicals Policy 2030 – building on the past, moving to thefuture”.
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Future of the EU chemicals policy – current discussions
EU Parliament discussed, yesterday, the results of the FitnessCheck.
EU Parliament discussion, today, on the “EnvironmentImplementation Review 2019 – A Europe that protects itscitizens and enhances their quality of life”.
• REACH is specifically addressed, in particular the registration dossiers.
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Our vision for the EU chemicals policy after 2019
The EU chemical policy framework is unique and the mostambitious in the world.
EU will continue to drive an ambitious chemicals policy, moreglobal sustainability standards will be developed and circulareconomy will be the norm. In parallel, the chemical industry needsto be recognised as an indispensable provider of safe, sustainableand innovative solutions.
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EU Chemicals policy after 2019
4. Integrate circular economy in risk
management- align chemical and waste
policies,- clarify which substances
may be problematic,- update RA/RM
methodologies for circularity,
- integrate all relevant SDGs in decision-making
2. Increase regulatory
predictability- improve and
harmonise Risk Management
Options Analysis (RMOA)
5. Explore opportunities to
reduce regulatory gaps
between EU and other
regions
3. Better integrate science into decision-making
- engage academic scientists in ECHA and/or COM processes,
- improve MS expert resourcing,
- harmonise risk assessment practices across EU agencies
1. Consolidate foundations
- improve implementation of REACH and CLP in complex areas and
step up enforcement
6. Work together to
increase trust in the EU chemical RA/RM system
In alignment with REACH Review Actions 1, 3 and 12:
• Solve issues around quality/compliance/update of registration dossiersissues via effective implementation of Action Plans, commitments andpartnerships.
• Clarify requirements on Exposure Scenarios.
• Promote uptake of IT-tools and methodologies developed by ENES.
• Enhance information flows on safe use of chemicals from manufacturing allthe way through to consumers, recyclers and waste operators.
• Embrace digital communication.
1. Consolidate foundations
- improve implementation of REACH and CLP in complex areas and
step up enforcement
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Commission-ECHA ‘REACH Evaluation Joint Action Plan’
• The Joint Action Plan is ECHA’s and theCommission’s answer to address the lack ofcompliance of the information in theregistration dossiers.
• It also requires:o commitment from authorities to make the process
more efficient;
o industry to review their dossiers and generatefurther information as needed.
• The substances concerned are the 16.500substances registered in full in 66.000dossiers as of end 2018.
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https://cefic.org/our-industry/reach-dossier-improvement-action-plan
• Systematically integrate use and socio-economic elements in RMOA (SEAinformation level equivalent to an Impact Assessment).
• Structure, harmonise and guide choice of risk management measures (RMM)according to uses (e.g. process chemicals, monomers can be manageddifferently from dispersive or consumer uses), develop decision trees.
• ECHA to coordinate RMOA conclusions across Member States by formalising therole of RiME (Risk management and evaluation platform) to avoid multipleregulatory initiatives on the same substance, i.e. target ‘One substance-oneRMOA-one RMM at a time’.
2. Increase regulatory
predictability- improve and
harmonise Risk Management
Options Analysis (RMOA)
In alignment with REACH Review Actions 7 and 11, andconsidering RMOA is regarded by most stakeholders asa voluntary, useful approach:
Acknowledging scientific input is a key component of decision-making,
• Engage academic scientists in the ECHA processes and align methodologieswith other EU agencies, particularly on emerging issues:
- endocrine disruptors assessment (screening and confirmatory approaches),
- persistency (case-by-case characterisation of emissions and risk levels),
- long-range transport assessment for POPs, consideration of ‘mobility’ topredict impact on ground- and drinking water,
- polymers assessment, robust method for grouping to avoid regrettablesubstitution).
3. Better integrate science into decision-making
- engage academic scientists in ECHA and/or COM processes,
- improve MS expert resourcing,
- harmonise risk assessment practices across EU agencies
• Establish the Scientific Advisory Mechanism (SAM) as an authoritative scientificbody: make SAM a permanent adviser to the ECHA Committees and Expertgroups and ensure the Commission’s regulatory proposals reflect SAM opinions.
• Member States should improve resourcing in the ECHA committees and expertgroups as the number of substances and regulatory decisions covered by thecommittees has accelerated and some dossiers become increasingly complex(broad restrictions, microplastics, relevant grouping).
• Explore scientific approaches to better estimate/monitor if/how persistentchemicals may build up in the environment and thereby reduce long-termuncertainty; and align approach across EU agencies (ECHA, EFSA, EMA).
• Develop a framework to increase transparency of scientific evidence whileprotecting CBI and IP, common to all EU agencies.
3. Better integrate science into
decision-making
• Clarify which substances are meaningful to communicate to ensure safe recyclingand waste management (avoid uncertainty from a shift SVHC – Substances of concern –
hazardous chemicals).
• Explore potential of new technologies (radio-frequency, blockchain) to improvetracking of substances and transparency.
• Harmonise waste classification.
• Update SEA and RMOA methodologies to fully integrate circular economy criteria:some trade-offs may be needed (e.g. durable materials are often persistent).
4. Integrate circular economy in risk
management- align chemical and waste
policies,- clarify which substances
may be problematic,- update RA/RM
methodologies for circularity,
- integrate all relevant SDGs in decision-making
To integrate circular economy drivers in risk assessmentand management:• Develop and implement practical and realistic
solutions to managing legacy chemicals, involving allactors in the chain (working groups, exchangeplatforms) at sectoral level
- Encourage chemical recycling as a solution toeliminate ‘legacy substances’.
2 examples of chemicals companies addressing plasticwaste with recycling solutions:
• BASF developed the ChemCycling project. Plastic waste will betransformed into a raw material using thermochemicalprocesses. The raw material can be used to create newchemical products with excellent product performance basedon recycled plastic waste.
• Dow intends to use a method that breaks down plastic into aform that can be used in a fresh round of manufacturing. Dowplans to implement the process at its plant in the Netherlands,and make it a recycling mainstay.
4. Integrate circular economy
in risk management
• Pursue full implementation of UN GHS in all countries.
• Explore potential of digital platform to optimise use of hazard data fromREACH across regions (to reduce animal testing, support developingcountries) while respecting IP; ultimately leading to some form of mutualrecognition of substance data and risk assessment.
• In emerging areas of common interest, explore opportunity for globalcoordination (e.g. safety assessment of polymers: opportunity for a global approach?).
5. Explore opportunities to
reduce regulatory gaps
between EU and other
regions
• Positive positioning of chemical policy achievements in the EUby all stakeholders.
6. Work together to
increase trust in the EU chemical RA/RM system
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To take home…
• REACH, due to its novelty, has been and is still learning-by-doing:let’s focus on the fundamentals and make it work before increasingthe ambition level
✓ Registration dossiers
✓ Extended SDS / exposure assessment
✓ Enhanced RMOA and RMM adapted to the use(s)
• REACH contributes to UN Sustainable Development Goals. So dochemicals (new materials, e.g. purification of water, food protection,energy efficiency, healthcare, etc)
✓ Need to find the right balance
✓ Need to reassure the public
• Substitution is one of several options, case-by-case, for managingchemical risks.
ChemistryCAN !https://chemistrycan.com/
Preserving wild fish stocks
Recycling food packaginginto school desks
Advanced chemical additives boost the quality of recycled paper
Designing with energy efficiencyin mind (“cool roofs”)
