Products – Substitution

Substitution of substances of concern

Many laws lay down rules governing the regulation of substances of most concern or even prohibit the use of such substances. The general objective is to replace these substances with safer alternatives, be they substances or technologies.

The European Chemicals Agency (ECHA) is aiming to identify all substances of very high concern (SVHC) by 2020, together with the EU’s member states. Up until now, the list of SVHC substances (candidate list) contains 173 entries. The use of 43 of these substances in Europe is, or will soon be, prohibited (Annex XIV of REACH), unless the user has been granted an authorization to use the substance for a specific, safe use for a fixed period.

The annual essenscia questionnaire reveals that as soon as a chemical is put on the candidate list, companies consider halting its use or try to replace it with a safer alternative. In early 2017, about half of the respondents indicated that they use, produce or import at least one of the 173 substances on the candidate list and one- fifth use, produce or import at least one of the Annex XIV substances. Nevertheless, there are currently no Belgian applications for authorization, according to the information available on the ECHA website. This is partially explained by the fact that the use of these substances by Belgian companies may be assessed in the application dossier of their upstream suppliers. In other cases, companies invest in innovations and are switching to safer alternatives before the sunset date, avoiding the need to apply for authorization.

The search for safe alternatives is usually a lengthy process that requires cooperation throughout the supply chain and re-approval or re-certification of the formulations. Often there is no one-to-one alternative that can be used in all applications. In evaluating possible alternatives, consideration needs to be given not only to the hazardous properties of the substance but also the associated risk throughout the lifetime of the product.  Substitution can be accelerated through legislation, but it is the market which determines whether an alternative is economically and technically viable or not.

Limiting the use of SVHCs in Europe for the production of certain articles implies a risk that the production chain will move outside Europe. The final article, containing the SVHC, will then be imported from outside Europe. To protect consumers and the environment globally and to guarantee a level playing field for European industry, imported articles must comply with the EU’s high standards as well. The import of articles containing substances that are forbidden or restricted in Europe not only puts consumers and the environment at risk, but also jeopardises moves towards more post-consumer recycling and a circular economy.

Enforcement is obviously crucial to guarantee that imported articles containing SVHCs or restricted substances comply with the European legislation. Analysis of the reported non-conformity of products in the European RAPEX system shows that in more than 25% of the cases, this concerns toys, followed by cosmetics and textiles. China is the country of origin in more than 40% of cases of non-conformity, followed by the US and India (10% each). A quarter of infringements are related to a too-high concentration of phtalates in products (e.g. toys), followed by presence of chrome VI (e.g. leather shoes) in 12% of cases.

Objective information in layman’s language is hard to find. essenscia therefore supports the GreenFacts Initiative to translate the available reviews into Dutch. GreenFacts is a non-profit project which brings complex scientific consensus reports on health and the environment (from, for example, international organisations such as the WHO, FAO, IARC, UNEP, and the European Commission) within the reach of non-specialists. GreenFacts publishes clear, faithful and verified summaries of existing scientific reports on health, the environment and sustainable development. These are peer reviewed under the control of an independent Scientific Committee.

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