Safe and Sustainable by Design – where from, where to?

Recently, EuChemS, jointly with GDCh, commented on the pilot of the European Commission’s “Safe and Sustainable by Design” (SSbD) framework. But what are the origins of this initiative. What may the future hold for it, and where does EuChemS enter into the picture?
Marton Kottmayer,
EuChemS

EU-wide regulatory context for chemicals

EU regulations on potentially hazardous chemicals have been around for a long time in order to protect human health and the environment. However, the basis of the current framework is only a little over one and a half decades old. The EU’s  “Registration, Evaluation and Authorisation of Chemicals” (REACH) regulation, which entered into force in 2007 is still considered as one of the key legislative achievements of the European Union. Under the umbrella of this framework, many important chemical policy decisions were made, such as the establishment of the European Chemicals Agency  (of which EuChemS is a registered stakeholder), and the “Classification, Labelling and Packaging” regulation. However, as the importance of sustainability became increasingly apparent, many began calling this monumental regulation outdated, and called for an equally monumental revision of it.

Chemicals Strategy for Sustainability

To ensure that REACH adequately responds to the increasing sustainability challenges, the Commission launched the “Chemicals Strategy for Sustainability Towards a Toxic-Free Environment” (CSS) in 2020 (connected to the  Zero Pollution strategy, of which EuChemS is also a stakeholder). The shaping of this strategy is an ongoing cooperative process between the Commission and a number of stakeholders.

A long-time open dossier

The REACH revision is, to say at the least, is a sensitive area of Commission-Parliament negotiations, as the latter institution considers that the former one wastes time due to political and lobbying related reasons, while the Commission believes that the Parliament calls for timelines that won’t allow enough time to create a robust proposal. The details of the discussions are beyond the scope of this article, but as a bottom line, the completion of the REACH revision may take some time.

A long-time open dossier

The REACH revision is, to say at the least, a sensitive area of Commission-Parliament negotiations, as the latter institution considers that the former one wastes time due to political and lobbying related reasons, while the Commission believes that the Parliament calls for timelines that won’t allow enough time to create a robust proposal. The details of the discussions are beyond the scope of this article, but as a bottom line, the completion of the REACH revision may take some time. 

CSS set out to address health and environmental hazards, not only in products that are already in the market, but has also the ambition of ensuring that novel products meet safety and sustainability standards. This is where the Safe and Sustainable by Design (SSbD) initiative originates from: it aims to set out guidelines that are considered during the phases of research innovation and development. 

Balancing sustainability and competitiveness

This Chemicals Strategy for Sustainability is also a result of the previous EU legislature’s elevated focus on sustainability. However, this focus was slightly changed in the 2024-2029 strategic priorities, as now it is partnered with competitiveness-related and economic considerations. However, SSbD can be one of the key links that connect competitiveness and sustainability, as it has the potential to provide great incentives to market innovation – as long as it is done in a sustainable way. 

Balancing sustainability and competitiveness

This Chemicals Strategy for Sustainability is also a result of the previous EU legislature’s elevated focus on sustainability. However, this focus was slightly changed in the 2024-2029 strategic priorities, as now it is partnered with competitiveness-related and economic considerations. However, SSbD can be one of the key links that connects competitiveness and sustainability, as in it has the potential to provide great incentives to market innovation – as long as it is done in a sustainable way.

Contributions of EuChemS

SSbD aroused the interests of a wide range of chemistry-related organisations: amongst others, The European Chemical Industry Council (CEFIC) and the Partnership for the Assessment of Risks from Chemicals (PARC)  had comments related to the topic – and EuChemS is no exception. You may have read about EuChemS’ participation in the “High Level Roundtable on the Implementation of the CSS”. The first meeting of this roundtable was held on 1 February 2023, where stakeholders were consulted on SSbD. EuChemS highlighted that chemical education is an indispensable component of SSbD, as SSbD focuses on the R&I phase, and research and development will be undertaken by future generations of chemists. EuChemS consistently emphasised this point, including in its most recent press release. However, in this press release, this focus on education was given another dimension: in order to properly educate students of chemistry on how to handle potentially hazardous chemicals safely and sustainably, these hazardous chemicals should be permitted at least in an educational context. Therefore, in its  most recent contribution on SSbD,  EuchemS advises against blanket bans on entire classes of chemicals, as some exceptions, such as educational ones, would conversely contribute to a safer and more sustainable chemistry landscape. 

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