A couple of years ago the History Channel had one of its biggest successes to date with the show Ice Road Truckers. The show followed truck drivers that were hauling cargo in 12-hour shifts, driving over frozen lakes in complete darkness. The hook of Ice Road Truckers was that it was framed as “the world’s toughest job”.
But I say forget those Ice Road Truckers – the world’s toughest job has to be that of a middle manager. Always on the receiving end of criticism from all parties. And since it’s impossible to please everyone, you’re constantly stuck between a rock and hard place.
“ChemSec has definitely doled out its fair share of criticism towards ECHA throughout the years, but this time I would actually like to praise the agency for doing something really, really good”
When I think about it, the middle manager of chemical Europe has got to be ECHA. Say this, and industry complains, say that, and NGOs criticize, and so forth.
ChemSec has definitely doled out its fair share of criticism towards ECHA throughout the years, but this time I would actually like to praise the agency for doing something really, really good.
It has been tasked with building a database that will include all EU Candidate List chemicals in all products placed on the EU market. I will admit it – the scope is a bit crazy. But more importantly: It will be really great when it’s finished.
And despite all uncertainties and parties complaining about how this database is “impossible”, ECHA – the middle manager – is approaching its task with the intention to really make this work.
If you never heard about this database it’s totally understandable. It seemingly came out of nowhere this year and wasn’t preceded by any stakeholder opinions or impact assessments, which actually feels a bit refreshing in a time where necessary environmental legislation tends to be discussed for ages rather than swiftly implemented.
One of its purposes is to serve recyclers with information about the chemical content in the things that they are converting into new materials. Chemical transparency is something ChemSec, as well as many brands, has been screaming about for years.
It’s essential in order to increase the value of recycled materials, and I urge all recyclers to see the potential here: you will be able to sell your product at an increased price to a whole new set of customers.
Because the truth is that today recyclers can’t deliver the level of material transparency that many brands are asking for. This fact keeps virgin material and finite resources in high demand and is a real barrier for circular economy.
Nevertheless, the surprise launch of this database initiative made it so that many stakeholders in the chemical space were caught a bit off guard. It wasn’t until late summer that the actual impact of it started to sink in.
Naturally, this has raised the temperature in chemical Europe and some corporate people are now complaining to ECHA.
“Because the truth is that today recyclers can’t deliver the level of material transparency that many brands are asking for”
No doubt, some industries will have a tough time to comply with this new obligation. But on the other hand, many will do just fine. Several consumer-close companies, such as those in the electronics industry, have a good understanding of what is in their products.
I do understand, however, that many companies feel they have too low margins and that their profit is simply not enough to cover the additional work required to shed a light on the chemical content of their products.
But if you think about it, this is really no different than consumers asking about Substances of Very High Concern in products – something they have had the right to do for 10 years already according to article 33 in REACH. The only difference is that instead of being required to produce an answer within 45 days, companies now have a couple of years to come up with it since they’re not liable to report to the database until 2021.
Looking at it from this angle, the database can actually be considered somewhat of a relief.
Still, some call it impossible and crazy, claiming it will never work. There are simply too many articles to cover. Jokingly, I heard people say it’s going to be the largest database the world has ever seen, and that computer server companies have an opportunity for a once-in-a-lifetime tender here.
But, so what if it’s crazy? Some of history’s greatest achievements started as crazy ideas.
I’ll tell you what is crazy: not knowing which hazardous chemicals are in the products we produce, sell and buy.
I’d like to argue that a database that can help us understand some of the toxic chemicals we surround ourselves with is pretty solid idea. And imagine the possibilities: What if it wasn’t limited to Candidate List substances, but could also include SIN List chemicals, or better yet, full material declarations? This would seriously incentivize the use of recycled materials as well as increase the value of the industry.
Personally, I believe the discussions around how to design it should revolve around what we want to achieve, not what technique is currently available. We know from experience that legislation drives innovation and this could become the perfect example of that.
And as always, there are huge business opportunities here. You just have to be able to think outside the box.
Executive Director, ChemSec