In October 2020, the European Union presented its Chemicals Strategy for Sustainability (CSS), which is part of the European Green Deal. The Green Deal is inherent to the United Nations' 2030 Agenda and aims to eliminate pollution and achieve a healthy and toxic-free environment.
In May 2021, the European Commission launched two inception impact assessments on the reopening of the CLP (Classification, Labelling and Packaging) and REACH (Registration, Evaluation, Authorisation of Chemicals) regulations. These inception impact assessments aim to evaluate the environmental, economic and social consequences of the proposed updates, the actors that will be affected, taking into account feedback from stakeholders and experts.
The feedback periods for these impact assessments have closed and the reports are scheduled for release in the spring and summer of 2022.
The CLP regulation, if reopened, could be modified on several points:
With regard to the REACH regulation, the planned changes could include for example:
If you wish to participate in the public consultation related to the reopening of the REACH regulation, you can keep up to date with its opening (scheduled for the first quarter of 2022) here. The public consultation related to the CLP regulation is already closed.
The chemical industry could lose 12% of its substance portfolio by 2040, according to a report published by Cefic (European Chemical Industry Council). The main factors contributing to this loss are the extension of the Generic Risk Approach (GRA), and the addition of new hazard classes in the CLP regulation. It is estimated that nearly 12,000 substances could be affected by these proposed changes.
Downstream users are likely to be most affected by these changes, particularly through the following sectors:
The loss of turnover for the chemical industry is estimated between 47 and 81 billion euros annually between 2023 and 2040 by Cefic, due to the decrease in the production and use of products containing these substances, or the increase in production costs.
Cefic is expected to continue its evaluation in a second phase, which will address the assessment factor for mixtures, registration obligations for polymers, the ban on PFAS, the application of an export ban and the extension of REACH registration obligations to substances produced in lower tonnages.
The European Environmental Bureau, or EEB, a European NGO dedicated to the environment, believes that the Cefic report shows the need for additional regulatory action.
The NGO estimates that this loss of 12% of the chemical industry's substance portfolio means that millions of products intended for consumers and professionals potentially contain substances that are dangerous or of concern for health or the environment.
EEB also adds that the Cefic report does not take into account the longer term issues of these revision proposals, notably with the increase in substitution for safer alternatives and thus the desire to reduce the estimated costs for industry. The impacts on health and the environment are also not taken into account.
EcoMundo�s recommendation: just as with the implementation of REACH some 15 years ago, the chemical industry sees above all the economic costs. Although these costs are important, they will not prevent regulations from making their way in the European Union towards a healthy environment. We therefore advise you to start auditing your chemical portfolios now to determine the extent of the consequences for your industry. Our experts are able to accompany you throughout these audits.
For more information, do not hesitate to contact one of our experts!
In October 2020, the European Union presented its Chemicals Strategy for Sustainability (CSS), which is part of the European Green Deal. The Green Deal is inherent to the United Nations' 2030 Agenda and aims to eliminate pollution and achieve a healthy and toxic-free environment.
In May 2021, the European Commission launched two inception impact assessments on the reopening of the CLP (Classification, Labelling and Packaging) and REACH (Registration, Evaluation, Authorisation of Chemicals) regulations. These inception impact assessments aim to evaluate the environmental, economic and social consequences of the proposed updates, the actors that will be affected, taking into account feedback from stakeholders and experts.
The feedback periods for these impact assessments have closed and the reports are scheduled for release in the spring and summer of 2022.
The CLP regulation, if reopened, could be modified on several points:
With regard to the REACH regulation, the planned changes could include for example:
If you wish to participate in the public consultation related to the reopening of the REACH regulation, you can keep up to date with its opening (scheduled for the first quarter of 2022) here. The public consultation related to the CLP regulation is already closed.
The chemical industry could lose 12% of its substance portfolio by 2040, according to a report published by Cefic (European Chemical Industry Council). The main factors contributing to this loss are the extension of the Generic Risk Approach (GRA), and the addition of new hazard classes in the CLP regulation. It is estimated that nearly 12,000 substances could be affected by these proposed changes.
Downstream users are likely to be most affected by these changes, particularly through the following sectors:
The loss of turnover for the chemical industry is estimated between 47 and 81 billion euros annually between 2023 and 2040 by Cefic, due to the decrease in the production and use of products containing these substances, or the increase in production costs.
Cefic is expected to continue its evaluation in a second phase, which will address the assessment factor for mixtures, registration obligations for polymers, the ban on PFAS, the application of an export ban and the extension of REACH registration obligations to substances produced in lower tonnages.
The European Environmental Bureau, or EEB, a European NGO dedicated to the environment, believes that the Cefic report shows the need for additional regulatory action.
The NGO estimates that this loss of 12% of the chemical industry's substance portfolio means that millions of products intended for consumers and professionals potentially contain substances that are dangerous or of concern for health or the environment.
EEB also adds that the Cefic report does not take into account the longer term issues of these revision proposals, notably with the increase in substitution for safer alternatives and thus the desire to reduce the estimated costs for industry. The impacts on health and the environment are also not taken into account.
EcoMundo�s recommendation: just as with the implementation of REACH some 15 years ago, the chemical industry sees above all the economic costs. Although these costs are important, they will not prevent regulations from making their way in the European Union towards a healthy environment. We therefore advise you to start auditing your chemical portfolios now to determine the extent of the consequences for your industry. Our experts are able to accompany you throughout these audits.
For more information, do not hesitate to contact one of our experts!