A recent policy brief from the European Environmental Bureau (EEB, a large network of environmental NGOs) entitled “Integrating the toxic-free environment goal into product policy” opens with the following very clear statement:

The key guiding principle of the Chemicals Strategy for Sustainability (CSS) published in October 2020 is to eliminate hazardous substances from products. The EU Green Deal acknowledges that chemical pollution is detrimental to both human health and ecosystems. The design of products including the material composition, their production processes, their final treatment and controlled material loops play a key role in shifting towards a toxic-free environment in a circular economy. Effective measures include the substitution of hazardous substances and reducing the overall level of consumption. 

The whole document can be found at:


On 23 June 2021 ChemSec ran a webinar entitled “When is it justified to use very hazardous chemicals?” with the introductory words ‘The EU’s Chemical Strategy acknowledges the urgency to speed up the phaseout of hazardous chemicals, and one important step in that direction is to allow the most harmful chemicals only for “essential use”.’

ChemSec sees the title of the webinar as a focussed question that is more compelling than discussion about what constitutes essential use. ChemSec set out a decision tree for assessment of justification.

See https://chemsec.org/webinar-when-is-it-justified-to-use-hazardous-chemicals/ 

The EEB briefing calls for more transparency in supply chains in respect of products containing hazardous substances. It also sets out reasons why REACH is insufficient to promote substitution.

All stakeholders should take note of what these bodies are saying, since they seem to have a big influence on the attitudes of many regulators.

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