The E.U. is reassessing the fitness of the whole package of chemicals management legislation, including REACH, with sustainability in mind.
A new piece of legislation developed as part of the European Green Deal is the Chemicals Strategy for Sustainability (toxic-free E.U. environment) framework. This is on track, the roadmap consultation feedback period having ended in June 2020. Over 50 new actions were presented in October with the aim of protecting the environment and promoting the circular economy. These affect not only the chemicals industry but downstream users such as tape manufacturers.
A key aspect of the roadmap includes simplifying substance assessment. Currently there are 3 potential European organisations that can assess substances for different purposes: ECHA (the European Chemicals Agency), EFSA (the European Food Safety Agency) and EMA (the European Medicines Agency). Sometimes they have to address substances within different legislative frameworks, and they can also issue different outcomes. This is something the Strategy aims to streamline.
Specifying the risks associated with endocrine disruptors (e.g. BPA), an emerging topic of the last few years, is also something that this initiative aims to achieve.
The Chemicals Strategy for Sustainability is also focussed on levelling the playing field for European manufacturers and importers, who sometimes free-ride on schemes that European manufacturers cannot avoid. This ultimately results in lower protection of human health and environment.
Combined assessment of simultaneous exposure to multiple substances is seen as important to the European Commission. Currently evaluation of mixtures is not clearly regulated. They also want to target very persistent chemicals, such as polyfluorinated substances (PFAs).
The framework of this initiative will include a definition of sustainable chemicals having to do with how well a chemical can be put into the circular economy in terms of its recyclability. And furthermore, whether the chemical is an impurity that would affect the recyclability of some waste streams that then would prevent the reuse of these recyclates in highly valued materials.
During the Safer Chemicals Conference 2020 organised by ECHA, Director Bjorn Hansen’s presentation revealed that there will be a definition of sustainability established at all levels within Europe for sustainable products, practices and chemicals. The definitions will be ongoing but will likely take into account the capacity of chemicals to enable the circularity of products, i.e. how recyclable a product will end up being because of the properties of specific chemicals it contains.
The European Chemical Industry Council (Cefic) has been active in responding to the CSS, having set up a cross-industry platform to include the voices of its members, chemical manufacturers, and downstream users such as tape manufacturers to collaborate on addressing relevant topics.
Afera is a member of a CSS Cefic subgroup addressing Essential Uses, a major discussion point over the entire industry. They are zeroing in on an industry position on determining what constitutes an SoC (substance of concern) and essential use of a substance; nonessential uses of substances of concern will potentially be banned.
Our tape industry collective is also a member of the MAF (mixture assessment factors) subgroup. This will add another assessment factor to measuring risk of chemicals included in mixtures. This could mean that many uses of chemicals in formulations that were considered safe before may no longer be designated as such.
Another subgroup Afera is involved in is Sustainable by Design. CSS brings potential changes to a number of regulations affecting articles and products linked to the adhesive tape industry.
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