This assessment from the Lowell Center is based on a survey carried out on the different actors of the European Chemical industry (companies and consultants), EU Member States, the European Commission and NGOs.
The current capacity of the European market
No enough investment in SVHC substitution
REACH is a regulatory driver that has enabled to motivate the chemical industry in SVHC substitution. 81% of companies surveyed have substituted hazardous substances in their products in the last 10 years. However, regulatory measures can be inefficient if not aided by necessary (technical and financial) capacity and resources. It seems that Competent Authorities (ECHA, Commission, Member States, etc.) are concentrating on hazards and exposure data collection as well as the need to manage these substances’ chemical risk.
A lack of competent staff to study alternatives
Very little staff is dedicated to the research and evaluation of SVHC alternatives, which slows down to substitution activities, sharing of resources and coordination between authorities. Several elements from alternatives studies could be improved such as:
- Scoping/screening: the range of choice is often too restricted
- Technical feasibility: lack of technical knowledge from the authorities and lack of time and information for companies
- Economic feasibility: calculating the total cost of substitution is difficult to estimate on the long-term
- Hazard/exposure assessment: lack of consistency in the importance of the risk assessed
- Decision approach in the choice of the alternative
SVHC substitution is not a priority
In Europe, the company needs in substitution are disconnected from the priorities of academic research and private centres (not enough public or private investment). Only a few Member States have taken initiatives towards this goal. What’s more, the information collected with REACH cannot be used in to identify alternatives in its current form.
Even if efforts are made in information sharing and coordination of authorities, additional collaboration would be beneficial on the long term so as to involve the less active Member States.
The Lowell centre recommendations
Building infrastructures to support substitution
ECHA and Member State staff should be increased and trained on the challenges of SVHC substitution. They would have expertise in chemical risk assessment, technical feasibility, economic analysis in order to support and train other authorities and industries.
The authorities and the industry could be supported by the implementation of an online information centre regrouping experts that are trained in the analysis of alternatives and in substitution processes. Moreover, companies, especially SMEs would be assisted by technical support on a national and European level.
The grant system should coordinate with the public and private investments so that more finances can be granted to « green » chemical substance research and innovation. Just like the Safer Choice Program of the United States Environmental Protection Agency, ECHA could develop a “safer chemical ingredient” list by using REACH data and third party certification.
Increasing the engagement and collaboration of authorities
ECHA could establish an inter-authority committee that would regroup to talk about substitution, share information, collaborate and identify concrete projects in SVHC substitution. Improving communication between the different supply chain actors could also improve their collaboration.
Enhancing technical capacity to support the analysis of alternatives
Developing detailed guidance by ECHA that specify the minimum components and quality criteria needed for the analysis of alternatives would be great help for Authorisation applications. Moreover, ECHA could study the feasibility of a training programme on the analysis of alternatives.
Available data gathered under REACH as well as different resources on substitution could also help create online databases to aid in the screening and evaluation of alternatives.
Many challenges to overcome for the authorities
Identification, evaluation and adoption of SVHC substitution can be enhanced. Chemical regulations have provided a motivation but this has to be supported by placing companies that are leaders in hazardous substance substitution as drivers. ECHA can support these initiatives by:
- Improving the capacity and resources of the analysis of alternatives
- Supporting substitution activities
- Sharing informations and collaborating
For this, ECHA can use its authority to strengthen the SVHC substitution goal, before even regulating these processes.
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