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This is how the Restriction Roadmap can help speed up the journey towards our non-toxic destination

Policy

This is how the Restriction Roadmap can help speed up the journey towards our non-toxic destination

Published on 17 Jun 2021

We need to pick up the pace when it comes to banning hazardous chemicals from consumer products. The Chemical Strategy recognizes this and outlines an ambitious plan going forward. But legislation takes time. The Restriction Roadmap, based on current regulations, promises us a head start until the new system is in place.

It has been 15 years since the implementation of REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), and 12 years since the CLP (Classification, Labelling and Packaging of substances and mixtures) regulation came into force.

“Banning substances of concern one at a time clearly isn’t getting us anywhere fast”

Yet there are still hazardous chemicals in consumer products, a fact that worries 84% of the European population – and rightly so. This is a failure. Banning substances of concern one at a time clearly isn’t getting us anywhere fast.

A stricter and more generic approach

The Chemicals Strategy for Sustainability, published last fall, acknowledges the gravity of the situation and commits to “ensure that consumer products […] do not contain chemicals that cause cancers, gene mutations, affect the reproductive or the endocrine system, or are persistent and bioaccumulative”.

“As if these phrasings were not encouraging enough, the next part […] really makes our hearts skip a beat”

The strategy also commits to extend the same approach to “further harmful chemicals, including those affecting the immune, neurological or respiratory systems and chemicals toxic to a specific organ”.

As if these phrasings were not encouraging enough, the next part – acknowledging that it will take time to revise REACH and the CLP according to the strategy – really makes our hearts skip a beat:

“In the meantime, while the generic approach to risk management is not in place, prioritise all the above-listed substances for restrictions for all uses and through grouping, instead of regulating them one by one.”

The time to act is now

This is excellent and most welcome news, as it highlights the importance of acting now – before the revised regulations are in place – by introducing the concept of a Restriction Roadmap, using the current system to the furthest extent possible. ChemSec’s Deputy Director Frida Hök stresses the urgency of the European Commission getting to work:

“The aims of the Chemical Strategy to phase out ALL substances of very high concern from all consumer products gave us that ‘wow’ feeling. Now it’s up to the European Commission to put words into action and start delivering on that sentiment, using the tools we already have.”

We propose that the Commission start by banning the following substances from consumer products:

“Now it’s up to the European Commission to put words into action and start delivering on that sentiment, using the tools we already have”

  • All classified CMRs (Carcinogens, Mutagens and substances toxic to Reproduction), using the REACH fast-track approach
  • All SVHCs (Substances of Very High Concern) on the Candidate List
  • All SVHCs on the SIN List chemicals, using a priority substance group approach (according to the list below)

The grouping approach is key, but also to use the information we already have, in order to achieve these necessary and broad restrictions in a reasonable amount of time.

”Both consumers and companies are expecting tougher restrictions on substances of very high concern, and failing them is not an option. All eyes will be on the European Commission going forward. We will be there – providing as much expertise and guidance as we possibly can, while also keeping a watchful eye on the process”, Frida Hök concludes.

SIN List chemical groups to restrict in the first step

  • Fluorinated compounds: Including PFAS, called “forever chemicals” due to their extreme persistence in the environment. Widespread use in everything from dental floss to clothes and firefighting foams.
  • Phthalates: Mainly used as softeners in plastics. Endocrine disrupting chemicals damaging fertility, mainly in men. Migrates easily from flooring, toys, prints, food packages or any material they are used in.
  • Bisphenols: Endocrine disrupting chemicals. Widely used in consumer products and frequently found in biomonitoring of both environmental samples and human tissues.
  • Halogenated compounds: Including the infamous brominated flame retardants. The toxic properties are several, including carcinogenicity, persistence and endocrine disruption. The chemicals are intentionally added to products to achieve flame retardance, but easily migrates over long distances.
  • Toxic metals and metalloids: A group of well-known toxics like arsenic, lead and cadmium.
  • Alkylphenols: Includes nonylphenol ethoxylates, used in detergents and widespread in the environment where the endocrine disrupting properties cause problems.