COMMISSION STAFF WORKING DOCUMENT Synopsis report summarising the feedback received in the context of the Chemicals Strategy for Sustainability Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Chemicals Strategy for Sustainability Towards a Toxic-Free Environment
Date: 2020-10-14
Institutions: Directorate-General for Environment, European Commission
Subjects: EU strategy, chemical product, chemicals legislation, endocrine disruptor, environmental protection, international cooperation, product safety, public consultation, public health, toxic substance

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.10.2020  SWD(2020) 248 final  COMMISSION STAFF WORKING DOCUMENT Synopsis report summarising the feedback received in the context of the Chemicals Strategy for Sustainability          Accompanying the document COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS Chemicals Strategy for Sustainability   Towards a Toxic-Free Environment                    {COM(2020) 667 final} - {SWD(2020) 225 final} - {SWD(2020) 247 final} - {SWD(2020) 249 final} - {SWD(2020) 250 final} - {SWD(2020) 251 final}  
 
 
1.  INTRODUCTION 

This  report  covers  feedback  and  input  from  citizens  and  administrations,  associations  and 
other organisations  (hereinafter  ‘stakeholders’) as regards the Commission roadmap1 on the 
Chemicals Strategy for Sustainability (hereinafter ‘the Strategy’), which was published on the 
‘Have  your say’ portal2. It also provides a broader overview of other feedback of relevance 
for the Strategy provided by stakeholders in previous public consultations. 

The  Commission  initiated  its  work  to  develop  the  Strategy  following  the  European  Green 
Deal3 call for the simplification and strengthening of existing chemical legislation in order to 
better  protect  human  health  and  the  environment  against  hazardous  chemicals,  encourage 
innovation  for  the  development  of  safe  and  sustainable  alternatives  and  to  increase  global 
competitiveness.  The  Strategy  is  the  first  initiative  under  the  European  Green  Deal’s 
objective of the zero pollution ambition for a toxic-free environment.  

For the purpose of this report, the assessment of the feedback to the roadmap of the Strategy 
has been structured following the five main pillars of the Strategy: strengthening health and 
environmental protection, boosting safe and sustainable chemicals, simplification of the legal 
framework  on  chemicals,  providing  a  comprehensive  and  transparent  knowledge  base,  and 
inspiring chemicals management globally.  

2.  BACKGROUND AND PREVIOUS CONSULTATIONS 

The Chemicals  Strategy  for Sustainability builds  on a number of reviews, studies and Staff 
Working Documents prepared by the Commission services, as well as on contributions from 
several stakeholders. Brief summaries of the outcome of previous consultations are provided 
below, while stakeholders’ feedback as obtained in the public consultation on the Roadmap is 
presented in Section 3 of this report.  

In particular, when developing the Strategy the Commission has taken into consideration the 
main findings of the following documents, as well as the feedback provided by stakeholders 
during their preparation: 

-  The ‘Communication on the implementation of the circular economy package: options to 
address  the  interface  between  chemical,  products  and  waste  legislation’  (adopted  in 
January 2018)4; 

-  The  ‘Commission  General  Report  on  the  operation  of  REACH  and  review  of  certain 

elements’, also known as the second REACH review (adopted in March 2018)5; 

-  The Commission Report on ‘Findings of the Fitness Check of the most relevant chemicals 
legislation (excluding REACH) and identified challenges, gaps and weaknesses’ (adopted 
in June 2019)6; 

-  Other  targeted  consultations  as  well  as  the  Staff  Working  Documents  (SWD) 

accompanying the Strategy: 

1 European Commission, Roadmap on the Chemicals Strategy for Sustainability. 
2 European Commission, Better Regulation Portal.  
3 COM(2019) 640.  
4 COM(2018) 032.  
5 European Commission, Second General Report on the operation of REACH. 
6 COM(2019) 264.  

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  on Poly- and perfluoroalkyl substances (PFAS); 

 

 

 

the  progress  report  on  the  assessment  and  management  of  combined  exposures  to 
multiple chemicals and associated risks; 

the Fitness Check on endocrine disruptors; 

the review of a number of provisions under article 138 of REACH; and  

  a synopsis report, summarising contributions received by external stakeholders. 

The Strategy also builds on various additional contributions from stakeholders not covered in 
the abovementioned documents, including in particular: 

-  Council  Presidency  information  note  on  the  ‘Policy  conference  “REACH  Forward” 

Brussels, 1 June 2016’ (published in June 2016)7 

-  Council  Conclusions  on  ‘Protection  of  human  health  and  the  environment  through  the 

sound management of chemicals’ (adopted in December 2016)8 

-  Special Eurobarometer survey on Chemical Safety (published in June 2017)9 
-  Council Conclusions on ‘Towards a Sustainable Chemicals Policy Strategy’ (adopted in 

June 2019)10 

-  Outcome  of  the  high-level  EU  Chemicals  Policy  2030  conference  (published  in  June 

2019)11 

-  European Parliament Resolution on the ‘Chemicals Strategy for Sustainability’ (adopted 

in July 202012), as well as other previous Resolutions on chemicals 

2.1. 

SPECIAL EUROBAROMETER ON CHEMICAL SAFETY 

A  Eurobarometer  survey  on  chemical  safety13  was  carried  out  from  26  November  to  5 
December  2016,  consisting  of  face-to-face  interviews  with  27 929  citizens  from  all  EU 
Member States. The results of this survey painted a mixed picture of public awareness of, and 
confidence in, the safety of chemical products.  

Around two-thirds of EU citizens were, to different extent, concerned about being exposed to 
hazardous chemicals in their daily life, including a quarter who were ‘very much’ concerned. 
At least  half in  every Member State are concerned.  Less  than half of respondents  said  they 
feel  well  informed  about  the  potential  dangers  of  the  chemicals  contained  in  consumer 
products,  although  there  were  considerable  variation  between  Member  States.  In  general, 
respondents  in  northern  Europe  tended  to  feel  better  informed,  especially  in  the  Nordic 
countries,  while  those  in  southern  Europe  tended  to  feel  less  well  informed.  There  are  two 
main sources of information used by the public on the potential dangers of chemicals: product 
labels and the media.  

7 Council of the European Union, Presidency information note on ‘Policy conference “REACH Forward”.  
8  Council  of  the  European  Union,  Conclusions  on  ‘Protection  of  human  health  and  the  environment  through  the  sound 
management of chemicals’.  
9 European Commission, Special Eurobarometer 456.  
10 Council of the European Union, ‘Conclusions on ‘Towards a Sustainable Chemicals Policy Strategy’.  
11 Ministry of Environment and Food of Denmark and European Commission, EU chemicals policy 2030 - report.  
12 European Parliament, Resolution on the Chemicals Strategy for Sustainability.  
13 European Commission, Special Eurobarometer 456.  

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Two  in  three  respondents  said  that  if  they  asked  whether  a  product  contains  particularly 
hazardous chemicals,  the seller was  required by law to  provide them with this information. 
Only  a  small  minority  did  not  think  this  was  the  case.  Awareness  and  comprehension  of 
hazard  pictograms  was  tested.  Awareness  and  comprehension  was  quite  high  for  certain 
pictograms, especially for the ‘flammability’ pictogram. However, only one in five said that 
they  had  seen  the  serious  health  hazard  pictogram  before,  and  just  one  in  six  knew  the 
meaning of the exclamation mark pictogram.  

Almost  half of respondents  thought  that chemical  products  were safe for  human health and 
the environment, although perceptions of safety varied considerably between Member States. 
At the same time, half of respondents said that the current level of regulation and standards in 
the EU was not high enough and should be increased.  

At the same time, respondents were more likely to think that product safety has improved in 
the  last  10-15  years  than  to  say  it  has  deteriorated.  They  were  also  inclined  to  think  that 
products manufactured in the EU contained safer chemicals than those imported from outside 
the EU, although three in ten said that none of the products were safe.  

There were varying perceptions of who currently has responsibility for ensuring the safety of 
chemicals contained in consumer products in the EU. There were also different views on who 
should  have  this  responsibility.  Three  in  ten  respondents  thought  this  responsibility  lies 
among multiple actors (i.e. EU authorities, national authorities or manufacturers), while more 
than  four  in  ten  respondents  thought  that  this  responsibility  should  lie  with  more  than  one 
actor.  

Overall, the survey findings indicated the need to better inform EU citizens about the safety 
of chemical products, and to clarify the concerns that many of them have. 

2.2. 

PUBLIC CONSULTATION SUPPORTING THE SECOND REACH REVIEW 
The  REACH  Regulation14  mandates  the  Commission  to  publish  every  five  years  a  general 
report on the operation of the Regulation, focused on its state of implementation. The review 
is based on reporting from Member States and the European Chemicals Agency (ECHA), as 
well  as  on  input  from  stakeholders.  For  the  preparation  of  the  second  REACH  review,  an 
open  public  consultation  took  place  from  28  October  2016  to  28  January  2017,  where  453 
replies were received15. An SME panel16 was also carried out through the Europe Enterprise 
Network  in  order  to  gather  views  on  relevant  issues  for  Small  and  Medium  Enterprises 
(SME). 

In general, stakeholders recognised that REACH was overall adequate to address most of the 
current challenges posed to it but a number of gaps and weaknesses were recognised. A few 

14  Regulation  (EC)  No  1907/2006  of  the  European  Parliament  and  of  the  Council  of  18  December  2006  concerning  the 
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, 
amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 
1488/94  as  well  as  Council  Directive  76/769/EEC  and  Commission  Directives  91/155/EEC,  93/67/EEC,  93/105/EC  and 
2000/21/EC. OJ L 396, 30.12.2006, p. 1–849 
15 More information can be found here: European Commission, Second REACH review, Annex II. 
16 European Commission, Final Summary Report on the SME panel. 

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stakeholders  considered  that  these  would  require  a  revision  of  the  Regulation,  while  most 
pointed to the need to improve its implementation. 

Businesses  mentioned  legal  stability  and  certainty  as  a  key  issue,  considering  predictability 
an  important  driver  for  business  decisions.  They  acknowledged  the  positive  effects  of 
REACH  in  terms  of  making  information  available  to  ensure  safe  use  of  chemicals  and 
stressed  the  need  to  reduce  burden  and  costs  (in  particular  for  SMEs)  and  to  minimise 
negative  impacts  on  innovation  and  competitiveness  of  EU  industry;  and  they  expressed 
support  for  risk-based  approaches.  They  also  highlighted  the  importance  of  a  level  playing 
field and harmonised enforcement, including at the EU borders. Coherence between REACH 
and other chemical legislations was another area where businesses showed concern.  

NGOs considered that REACH could deliver a higher level of protection of human health and 
environment, but that its potential had not been fully developed. In particular, they pointed at 
poor  quality  of  registration  dossiers  and  insufficient  information  on  safe  use  of  chemicals 
flowing  through  the  supply  chain  and  for  consumers.  They  also  considered  that  the 
authorisation  and  restriction  provisions  are  excessively  burdensome  and  lengthy,  leading  to 
slow  progress  in  substitution  and  phasing-out  of  hazardous  chemicals.  Due  to  such 
deficiencies, it was their shared view that general principles underlying REACH such as the 
‘no data, no market’, the shift in the burden of proof or the precautionary principle were not 
being applied in practice. 

Most  public  authorities  shared  the  view  that  REACH  had  succeeded  in  improving  the 
management  of  chemical  risks,  but  also  raised  concern  on  the  deficiencies  related  to  its 
implementation. Most Member States expressed doubts about the quality of data generated by 
industry,  in  their  view  insufficient  to  decide  on  the  need  for  regulatory  risk  management 
measures  and  thus  making  the  shift  of  the  burden  of  proof  incomplete.  Some  authorities 
acknowledged the challenges faced by SMEs in complying with REACH requirements. Some 
Member  States  did  not  favour  re-opening  REACH,  proposing  actions  to  improve 
implementation  within  the  existing  framework,  while  others  proposed  actions  outside  such 
framework to increase the speed of regulatory measures and minimise negative impacts. 

Trade  unions  considered  REACH  as  a  positive  development,  making  companies  better 
informed  about  the  risks  posed  by  chemicals  and  helping  to  improve  risk  management  and 
the safety of those workers using chemicals, also beyond the chemical industry. 

The SME panel consisted of a specific questionnaire tackling SME related issues in relation 
to  the  information  sources,  existing  support  mechanisms  and  effects  of  REACH,  and  their 
relation with authorities. Registration and testing as well as substitution of substances of very 
high  concern  (SVHCs)  were  the  main  cost  factors  indicated  by  the  companies.  The  main 
challenges  reported  were  the  complexity  of  the  Regulation,  the  obligation  to  communicate 
information  in  the supply  chain  as well as the access  to  data. Opportunities and benefits of 
REACH appeared in relation to the reduction of risks to workers and the environment, as well 
as to the substitution of hazardous substances. Administrative burden and market distortions 

4 

 
 
in favour of larger companies were also reported. Respondents also demanded more guidance 
and training tailored to the needs of SMEs, including support by authorities. 

2.3. 

PUBLIC CONSULTATION SUPPORTING THE FITNESS CHECK OF THE CHEMICALS 
LEGISLATION (EXCL. REACH) 

An open public consultation took place from 4 March to 27 May 2016, where 356 replies and 
21  position  papers  were  received.  In  addition,  targeted  consultations  and  workshops  were 
organised  and  two  Eurobarometer  surveys  (see  section  2.1  for  more  information  on  the 
survey  on  chemical  safety)  were  prepared.  Stakeholders  were  consulted  on  five  evaluation 
criteria, the main findings being the following: 

Effectiveness:  The  EU  chemicals  legislation  was  considered  to  be  moderately  effective  in 
reaching  its  goal  of  protecting  human  health  by  all  stakeholder  groups.  Regarding 
environmental protection, citizens and businesses considered it mostly effective, while public 
authorities  considered  it  moderately  effective  and  NGOs  and  consumer  associations  only 
slightly  effective.  Citizens,  businesses  and  public  authorities  considered  the  EU  chemicals 
legislation  as  mostly  effective  in  ensuring  a  well-functioning  internal  market,  while  civil 
society  considered  it  moderately  effective.  A  particular  concern  pertained  to  inconsistent 
enforcement  by  Member  States.  The  main  reasons  for  lower  effectiveness  were  that  the 
legislation is not adapted to issues at stake or that legislation is not effectively implemented. 

Efficiency:  Costs  derived  from  EU  chemical  legislation,  particularly  for  SMEs  but  also  for 
bigger  companies and public authorities, were considered an important  factor. On the other 
hand, the main benefits generated by the chemicals legislation were considered to be reducing 
the damage to the environment and reducing the exposure to toxic chemicals of consumers, 
citizens and workers. 

Coherence:  Industry  associations  and  companies  as  well  as  civil  society  representatives 
considered  the  chemicals  legislation  internally  inconsistent,  although  public  authorities  and 
citizens  were  more  ambivalent.  SMEs  also  had  more  nuanced  opinions.  All  stakeholders 
agreed  that  the  chemicals  legislation  contains  gaps,  missing  links  and  has  overlaps  (except 
NGOs on the latter). Although such issues were indeed identified, further analysis of position 
papers  presented  by  stakeholders  showed  that  inconsistencies  most  often  affect  specific 
aspects of functioning of some pieces of legislation while not compromising the functioning 
of the whole framework.  

Relevance:  Stakeholders  from  all  groups  considered  that  not  all  relevant  considerations  are 
taken into account in regulatory decision-making on risk management. Regarding the way the 
EU  legislative  framework  addresses  emerging  areas  of  concern,  opinions  varied:  slightly 
(civil society), moderately (citizens and public authorities) and mostly (industry associations 
and companies) sufficiently.  

EU  added  value:  Businesses,  public  authorities  and  civil  society  considered  the  chemicals 
legislation to have a high level of added value, while citizens considered the added value to 
be moderate. 

5 

 
 
2.4. 

PUBLIC  CONSULTATION  ON  THE  OPTIONS  TO  ADDRESS  THE  INTERFACE 
BETWEEN CHEMICALS, PRODUCTS AND WASTE 

An open public consultation run from 23 July to 29 October 2018 and in total 461 replies and 
40  position  papers  were  received.  Feedback  on  four  main  issues  identified  by  the 
Commission were sought and summarised in a report published in March 201917.  

Issue 1: Insufficient information on substances of concern in products and waste. Regarding 
the concept of ‘substances of concern’, two tentative definitions of the term were proposed, 
with  one  referring  to  SVHCs  and  to  hazardous  substances  classified  for  chronic  effects  in 
CLP18 Annex VI, and the  other definition referring to  SVHCs,  persistent  organic pollutants 
and substances  restricted under REACH  and other sectorial  (product) legislation. The latter 
seemed to give rise to a greater level of agreement from stakeholders, although industry and 
business  associations  were  critical  about  both  proposed  definitions.  Overall,  stakeholders 
welcomed  the  development  of  compulsory  information  systems,  observing  that  it  would  be 
useful  to  waste operators  and industry. Some respondents  expressed uncertainties regarding 
the  framework  for  implementation  and  the  real  benefits  of  introducing  such  a  system.  The 
development  of  sector-specific  approaches  was  highly  supported  across  all  stakeholder 
categories, as they were regarded as effective in addressing the particularities of each value-
chain. There was also strong support for the option to subject imported products to the same 
rules  applied  to  those  products  produced  within  the  EU,  and  attention  was  drawn  to  the 
related risks from uncontrolled e-commerce. 

Issue 2: Substances of concern in recycled products. Stakeholders raised concerns regarding 
the  issue  of  legacy  substances.  Businesses  in  general  supported  the  use  of  waste  streams 
containing  legacy  substances  only  when  a  safe  use  of  the  recovered  material  can  be 
guaranteed  and  defended  a  case-by-case  approach.  Recycling 
trade 
associations raised concerns about the costs associated with recycling of products that contain 
legacy  substances  and  the  obstacles  involved.  Some  NGOs  proposed  that  the  Commission 
should  adopt  ambitious  measures  to  avoid  recycling  legacy  substances.  Regarding  how 
legislation should apply to primary and secondary raw materials, NGOs were of the opinion 
that the same requirements should apply, while most businesses supported the use of different 
standards  for  primary  and  secondary  materials  so  as  not  to  jeopardise  the  viability  of 
recycling  activities.  By  contrast,  other  businesses  argued  that  the  use  of  the  same  rules  for 
primary and secondary materials would facilitate compliance with specific product legislation 
such as the Restriction of Hazardous Substances (RoHS)19 and Ecodesign Directives20.  

industries  and 

Issue  3:  Harmonised  end-of-waste  criteria.  The  majority  of  stakeholders  expressed  their 
concerns on the lack of harmonised end-of-waste rules  across the EU. NGOs supported the 

17  European  Commission,  Summary  report  on  the  public  consultation  on  the  main  issues  identified  in  the  Commission's 
Communication on the interface between chemical, product and waste legislation. 
18 Regulation (EC) No 1272/2008 of the European Parliament and of the Council of 16 December  2008 on classification, 
labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and 
amending Regulation (EC) No 1907/2006. OJ L 353, 31.12.2008, p. 1–1355. 
19 Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain 
hazardous substances in electrical and electronic equipment. OJ L 174, 1.7.2011, p. 88–110. 
20 Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for 
the setting of ecodesign requirements for energy-related products. OJ L 285, 31.10.2009, p. 10–35. 

6 

 
 
                                                           
option  that  recovered  materials  should  reach  the  end-of-waste  status  through  REACH 
registration of the recovered substances, whereas businesses highlighted that the removal of 
the REACH registration exemptions for recovered substances was not a viable solution, as it 
would create additional administrative burden for recyclers. In addition, businesses advocated 
for  the  inclusion  of  obligations  and/or  exemptions  under  REACH  to  facilitate  recycling  of 
waste. 

Issue  4:  Difficulties  in  applying  waste  classification  methodologies.  Businesses  called  for 
harmonised waste classification as well as for better enforcement and implementation of rules 
governing this matter at EU level. They had, however, divergent views on the practicality of 
alignment  between  the  rules  for  classification  of  waste  under  the  Waste  Framework 
Directive21  and  those  for  substances/mixtures  under  CLP.  The  use  of  bioavailability  as  an 
element  to  be  considered  in  hazard  classification  of  waste  raised  different  opinions  and 
concerns among the stakeholders.  

2.5.  HIGH-LEVEL ‘EU CHEMICALS POLICY 2030’ CONFERENCE 

Some 300 stakeholders, including more than 50 speakers and contributors, attended the high-
level  EU  Chemicals  Policy  2030  conference,  which  took  place  in  June  2019.  Six  thematic 
sessions were held and are summarised below. 

Session  1:  Promoting  green  and  sustainable  chemistry.  In  general,  there  was  alignment 
among stakeholders on goals and what needs to be done to overcome barriers to innovation. It 
was a shared view that  regulation alone  will not  drive  green  and sustainable chemistry  and 
that there is a need for policy that incentivises R&D and commercialisation across the value 
chain.  Participants  called  for  development  of  a  set  of  clear,  flexible  and  science-informed 
criteria for green and sustainable chemistry.  

Session  2:  Chemicals  in  a  circular  economy.  There  was  general  support  to  the  progressive 
phasing-out  of  substances  of  concern.  Businesses  stressed  the  need  for  an  EU  chemicals 
framework that maximises the value of materials without compromising safety, including by 
use of risk-based approaches. Harmonisation of end-of-waste criteria was strongly supported 
by  industry.  All  stakeholders  supported  that  appropriate  information  is  shared  across  value 
chains to ensure safe use and recycling. 

Session  3:  Improving  the  regulatory  framework.  There  was  a  shared  vision  of  a  coherent, 
harmonised and transparent EU chemicals and products policy. To achieve this, governance 
mechanisms to bring together regulators across chemical sectors should be established, data 
requirements  and  risk  assessment  methodologies  should  be  standardised  across  legislation 
and EU chemical safety databases should be fully connected and inter-operable. 

Session 4: Knowledge building, monitoring and early warning. The collective vision was to 
protect  more  effectively  human  health  and  the  environment  through  establishment  of  early 
warning  systems  targeting  key  chemicals  and  sensitive  species  and  by  creation  of  a 

21 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste. OJ L 312, 
22.11.2008, p. 3–30. 

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formalised science-policy  interface to  ensure better uptake of scientific findings into policy 
decisions.  

Session 5: Smarter communication, better protection and lower costs. The group’s vision was 
to  have  safe  and  sustainable  products  placed  on  the  EU  market  and  that  consumers  should 
have  access  to  simple,  understandable,  harmonised  and  science-based  information,  which 
empowers  them  to  make  informed  decisions  and  builds  trust  in  products.  There  should  be 
very strong enforcement of the EU chemicals legislation, thus creating a level playing field, 
including for online commerce. 

Session 6: Global challenges – sustainability, innovation and competitiveness. It was a shared 
vision  that  the  EU  policy  should  shape  the  global  policy  and  governance  towards 
sustainability, safety and innovation. In particular, industry envisioned a globally harmonised 
risk management system on chemicals and waste – where approaches and methodologies for 
hazard  assessment  and  risk  management  of  chemicals  are  aligned  and  shared  -  and  that  an 
integrated approach and sustainable products should be the main business model. ´The same 
high standards should apply for chemicals, products and waste irrespective of origin. 

3.  FEEDBACK  ON  THE  ROADMAP  ON  THE  CHEMICALS  STRATEGY  FOR 

SUSTAINABILITY 

Stakeholders had the opportunity to provide their feedback on the roadmap for the Strategy 
during  6  weeks,  from  9  May  to  20  June  2020.  During  this  period,  424  contributions  were 
received via the Better Regulation portal, while 17 ad hoc contributions were received by the 
Commission services via email or letter. 

Figure 1: distribution of feedback received by user type. 

The  stakeholders  represented  a  great  variety  of  sectors.  Over  half  of  the  respondents  were 
citizens, followed by business associations (18 %), NGOs (8 %), companies (7 %) and public 
authorities  (4 %).  Other  stakeholders,  including  academia,  environmental  and  consumer 

8 

 
 
 
organisations  and  trade  unions  represented  8 %  of  respondents.  Figure  1  offers  more 
disaggregated data on user types. French citizens sent 200 almost identical responses22.  

3.1.  GENERAL COMMENTS 

Several  stakeholders  provided  general  comments  regarding  the  state  of  play  of  chemicals 
legislation  or  the  scope  of  the  Strategy.  Some  of  them,  in  particular  public  authorities, 
referred to the health impacts of exposure to hazardous chemicals and the associated societal 
costs,  which  according  to  the  information  provided  by  them  amount  to  billions  of  Euro 
annually. Other stakeholders, in particular NGOs, built on this issue by pointing at the costs 
to society of exposure in particular to endocrine disruptors and carcinogenic substances at the 
workplace.  Businesses  mentioned  the  need  for  an  impact  assessment  of  the  Strategy  and 
careful consideration of the consequences of any change in the existing regulations. 

There  was  overall  support  among  public  authorities  and  NGOs,  citizens  and  consumer 
associations  for  a  Strategy  designed  as  a  cross-cutting  programme  to  achieve  a  toxic-free 
environment by contributing coherently to other EU policies. A number of public authorities 
consider  that  chemicals  management  is  an  integral  part  of  environmental  sustainability  and 
that the Strategy should contribute to achieving the Sustainable Development Goals (SDGs), 
climate  neutrality,  use  of  renewable  resources  and  circularity.  Stakeholders  also  mentioned 
the  importance  of  complementarity  with  other  major  Commission  initiatives  under  the 
European  Green  Deal,  such  as  Circular  Economy,  Farm-to-Fork,  Biodiversity  Strategy, 
Beating Cancer Plan and Pharmaceuticals Strategy.  

Some  respondents  considered  that  stronger  links  to  other  pieces  of  chemicals  legislation 
should  be  in  the  scope  of  the  Strategy,  e.g.  the  biocidal  and  plant  protection  products 
legislation23, including  Integrated Pest  Management.  Some stakeholders  also  referred to  the 
growing  importance  of  bio-based  chemicals  and  asked  for  them  to  be  covered  by  the 
Strategy. 

Businesses  emphasised  the  key  role  of  the  chemical  and  pharmaceutical  industry  regarding 
health and environmental protection as well as sustainable solutions to achieve the goals of 
the European Green Deal.  It was a generalised concern among industry and certain  citizens 
that  the  lack  of  Impact  Assessments  in  the  context  of  the  Strategy  might  have  large  and 
negative consequences. Some stakeholders argued for the preparation of SME-centred impact 
assessments.  

Most  citizens  were  concerned  about  exposure  to  chemicals  in  everyday  products  and  the 
failure,  in  their  opinion,  to  achieve  sound  management  of  chemicals.  In  this  regard,  some 
respondents  proposed  to  establish  a  hierarchy  of  actions  and  address  essential  and  non-
essential uses. Many stakeholders, particularly NGOs and citizens, also referred to the need to 
implement better the polluter pays principle by introducing a fee on chemicals, while others 

22 For the purposes of this report, these responses have been aggregated and considered as only one feedback. 
23 Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 October 2009 concerning the placing 
of plant protection products on the market; and Regulation (EU) No 528/2012 of the European Parliament and of the Council 
of 22 May 2012 concerning the making available on the market and use of biocidal products. 

9 

 
 
                                                           
pleaded  for  lower  fees  to  increase  competitiveness.  Animal  welfare  NGOs  suggested  the 
Commission to commit to phasing-out the use of animal testing.  

Finally,  many  respondents  from  different  stakeholder  groups  suggested  putting  more 
emphasis on nanomaterials, while others proposed to advance towards a full ban on certain 
materials and products like flame retardants or plastics. 

3.2.  STRENGTHENING  THE  EU  LEGAL  FRAMEWORK  TO  ADDRESS 

PRESSING HEALTH AND ENVIRONMENTAL CONCERNS 

Although  it  was  not  included  in  the  roadmap,  some  stakeholders  showed  support  for  the 
development of a toxic-free hierarchy for chemicals, pointing at the precautionary principle 
and to  the need to  apply it on a case-by-case basis.  Other stakeholders were  against such a 
hierarchy as, in their opinion, it is not based on scientific findings and would be contrary to 
the current combination of hazard and risk approaches.  

Public  authorities,  and  particularly  many  Member  States,  stressed  the  need  to  speed  up  the 
phasing  out  of  substances  of  concern,  including  groups  of  substances,  by  introducing 
restrictions that would only exempt essential uses. In particular, they mentioned the presence 
of  SVHCs  in  consumer  products  as  a  possible  focus  of  future  restrictions.  Businesses  in 
general  defended  maintaining  the  current  legislative  framework,  while  exploring  certain 
changes such as on harmonised classification for metal alloys or on nanomaterials. 

Some  stakeholders  also  brought  up  other  issues,  such  as  the  possibility  of  introducing  the 
principle  of  extended  producer  responsibility  (EPR),  along  with  new  fiscal  instruments 
(including  a  border  tax  for  SVHC  substances),  and  a  revision  of  the  food  contact  materials 
legislation.  Some  businesses  called  for  delayed  applications  of  certain  obligations,  such  as 
CLP classifications and adaptations to technical progress. 

Generally,  NGOs  considered  that  the  overall  exposure  to  chemicals  of  concern  should  be 
effectively  reduced,  including  by  phasing  out  SVHCs  and  setting  more  stringent  Binding 
Occupational  Exposure  Limits.  The  protection  of  vulnerable  groups  was  another  issue 
considered a priority by the majority of stakeholders. 

3.2.1.  Addressing endocrine disruptors 

The  majority  of  respondents  from  exposure  to  endocrine  disruptors  in  the  EU,  which 
amounted  to  between  EUR  157  and  270  billion  annually.  They  supported  an  effective  and 
coherent cross-sectoral system for identification and listing of endocrine disruptors, including 
suspected  ones,  to  minimise  exposure,  use  generic  risk  assessment  to  ban  them  (both 
confirmed  and  suspected)  in  all  types  of  consumer  products  and  to  ensure  consistent 
protection  level  for  vulnerable  groups.  Animal  welfare  NGOs  called  for  new  approaches 
avoiding the need for animal tests for identification of endocrine disruptors instead of using 
multigenerational animal tests. 

Academia stated that exposure to endocrine disruptors has been associated with a number of 
neurological,  metabolic  and  reproductive  effects  and  that  action  should  focus  on,  in 
particular, vulnerable groups. 

10 

 
 
3.2.2.  Addressing combination effects 

Although  there  was  generalised  support  for  actions  on  mixtures,  the  different  stakeholder 
groups  differed  in  the  suggested  actions.  Public  authorities  that  provided  views  considered 
that  combination  effects  should  be  addressed  in  all  relevant  chemicals  and  emissions 
legislation  by  introducing  a  pragmatic  solution.  Some  Member  States  considered  that  in 
REACH,  a  generic  mixture  assessment  factor  could  be  generally  applied  in  risk  or  safety 
assessments, except in cases where justified by specific use patterns or lifecycles. 

Businesses noted that intentionally produced mixtures are already regulated under CLP and 
REACH.  For  unintentional  mixtures,  they  suggested  to  identify  relevant  cases  where  risk 
assessment of individual chemicals have shown to be not sufficient and develop specific risk 
management procedures for these scenarios. Impact of the cocktail effect needs to be studied 
in  detail  with  all  stakeholders  with  the  aim  of  developing  constructive  proposals  based  on 
well-established scientific knowledge. In view of this, most of the businesses considered that 
a  mixture  assessment  factor  is  not  the  right  solution.  Some  companies  pointed  at  the  work 
done  by  the  European  Food  Safety  Authority  as  a  good  practice,  in  particular  with  its 
‘Guidance on harmonised methodologies for human health, animal health and ecological risk 
assessment of combined exposure to multiple chemicals’. 

NGOs, trade unions and consumer associations supported unambiguously the use of a generic 
mixture  assessment  factor  across  different  pieces  of  legislation  as  an  adequate  solution  for 
addressing mixtures. Daily exposure to mixtures of chemicals should be minimised to avoid 
cocktail effects, especially in vulnerable groups.  

Respondents  from  academia  agreed  that  the  evaluation  of  the  risk  of  exposure  to 
combinations of chemicals  is  a major challenge  and called for strengthening the legal  basis 
and  introducing  intermediate  measures  in  line  with  precautionary  approaches,  pointing 
concretely at a mixture assessment factor. 

3.2.3.  Addressing chemicals in the environment 

A broad majority of stakeholders from all groups supported action on chemicals affecting the 
environment, in particular regarding Per- and Polyfluoroalkyl Substances (PFAS). However, 
there were different views regarding the scope of the actions on these substances and on the 
need  for  grouping  approaches  (rather  than  individual,  per  substance  approaches)  for 
chemicals of concern. 

Most  public  authorities  called  for  speeding  up  identification  of  Substances  of  Very  High 
Concern  (SVHCs),  considering  that  new  hazard  classes  should  be  added  to  the  SVHC 
definition,  including  persistent  and  mobile  substances.  According  to  their  feedback,  a 
grouping  approach  should  be  implemented  to  avoid  regrettable  substitution  and  ensure 
coherent,  adequate,  consistent  and  highly  protective  measures.  They  also  overwhelmingly 
called for the Commission to develop an EU action plan for addressing PFAS, for which only 
essential uses should be allowed. For nanomaterials, some public authorities considered that a 
harmonised  and  legally  binding  definition  should  be  developed  followed  by  registration 
requirements set out in an independent legal cross-cutting instrument. 

11 

 
 
Many  businesses  emphasised  that  persistent  chemicals  should  be  regulated  if  a  risk  is 
identified. Others were supportive of the restriction of PFAS, particularly businesses affected 
by possible  contamination  from  these  chemicals.  Many businesses also  stated that potential 
mobility is not in their opinion suitable to inform on exposure. A few businesses complained 
about  EU  policies  being  contradictory,  as  some  substances  are  restricted  due  to 
environmental concerns while they are at the same time essential for batteries and electrical 
vehicles important for addressing climate change. Water-related businesses called for better 
control of micro-pollutants at source. 

NGOs  supported  regulating  very  persistent  chemicals  including,  but  not  only,  PFAS,  in  all 
relevant  chemical  legislation.  They  proposed  to  ban  all  non-essential  uses  of  persistent 
chemicals and chemicals that accumulate in the environment and to phase out all chemicals 
that are persistent, mobile and toxic.  

Both  NGOs  and  academia  considered  that  manufactured  nanomaterials  and  nanoparticles 
should be better  evaluated with  the aim of assessing their safety. Academia also  stated that 
highly persistent organic chemicals, in particular when also bioaccumulative or mobile, must 
be limited as  much as possible.  In particular, the production and use of the group of PFAS 
need to be brought under strict control, and only uses that are essential for society should be 
allowed.  

3.3.  SAFE AND SUSTAINABLE INNOVATION 

Stakeholders from all groups welcomed the focus on safe innovation and economic recovery 
presented in the roadmap. Many respondents considered issues such as increased investment 
in R&D, eco-design, faster substitution and competitiveness of EU companies as vital for the 
green and digital transition. Some respondents presented new ideas, such as chemical leasing, 
increased  support  from  EU  funds,  development  of  horizontal  criteria  for  sustainability  and 
extended exemptions for product and process-oriented research and development.  

The majority of stakeholders supported action at EU level to increase the strategic autonomy 
of  the  Union  in  the  production  of  essential  chemicals,  although  there  was  disagreement 
regarding  their  extent  and  focus.  Stakeholders  generally  agreed  on  the  need  to  use  this 
opportunity to improve the overall sustainability of the chemical sector.  

3.3.1.  Safe and sustainable by design 

Regarding the development of safe and sustainable by design criteria, stakeholders generally 
welcomed  this  idea  and  in  many  cases  offered  expertise  and  support  to  the  Commission. 
Some  stakeholders  provided  examples  of  other  criteria  being  developed  at  industrial  level, 
such  as  in  the  automotive  industry.  The  creation  of  an  EU  substitution  centre  to  put  in 
practice  these  criteria  was  also  recommended  by  a  broad  variety  of  stakeholders  from  all 
groups.  Some  stakeholders  requested  the  Commission  to  take  into  consideration  bio-based 
chemistry and the cascade use of biomass when developing criteria. 

More  concretely,  public  authorities  considered  that  both  innovation  and  competitiveness  of 
the  chemicals  industry  will  depend  on  its  ability  to  integrate  concepts  like  safe-by-design, 

12 

 
 
green  chemistry  and  new  business  models  into  the  production  and  use  of  chemicals.  They 
supported the idea of products being designed and produced in a way that preserves resources 
and prevents  negative impact, also  enabling non-toxic material  cycles.  They  also  suggested 
taking  into  consideration  the  economic,  social,  societal  and  environmental  impacts  in  an 
integrated approach.  

Businesses called for a Strategy that supports the industry’s green and sustainable transition 
through  a  progressive  and  gradual  process.  Among  the  ideas  presented,  incentives  and 
policies  like  tax  breaks  or  research  and  development  credits  as  well  as  establishing 
harmonised definitions of ‘safe’ and ‘sustainable’ were mentioned. They suggested to avoid 
substances of concern in the design phase and to employ a holistic approach also considering 
circular economy and resource efficiency in a robust eco-design policy. They called for the 
Commission to bear in  mind that production of many non-hazardous substances require the 
use  of  reactive  (hazardous)  starting  materials  that  can  be  handled  safely  in  an  industrial 
environment.  According  to  this  view,  the  sustainability  of  a  chemical  should  be  assessed 
holistically taking into account the specific uses during the entire lifecycle.  

NGOs, trade unions and consumer associations supported developing criteria for the safe-by-
design  concept  and  establishing  economic  incentives  to  support  substitution,  clean 
production, and frontrunner companies. They also considered that boosting innovation should 
not necessarily lead to placing more chemicals on the market. Academia promoted the shift to 
non-hazardous and renewable alternatives to prevent hazardous chemicals from being used in 
materials in the first place. The Commission should provide a framework securing that front-
runners with proactive business models can achieve competitive advantages. 

3.3.2.  Safe products and non-toxic material cycles 

Stakeholders gave a lot of attention to the issue of circular economy and proposed different 
solutions  to  the  main  issues  identified  within  the  roadmap  and  the  Communication  on  the 
interface  between  chemical,  products  and  waste  legislation.  There  was  overwhelming 
agreement  on  the  need  to  tackle  chemical  content  in  products,  particularly  in  imported 
products, as well as on the final ambition of ensuring clean waste streams. 

Public  authorities  strongly  supported  moving  towards  non-toxic  materials  cycles  with 
increased resource efficiency and reduced energy intensity and a transition to renewable raw 
materials.  In their view, the performance of recycling processes should be improved with  a 
view to reducing or controlling the content of hazardous chemicals in the recycled material, 
removing  legacy  chemicals  from  the  material  cycles  once  identified.  A  well-functioning 
internal market for high-quality and non-toxic secondary raw materials should be created. A 
network of regional authorities considered the use of sustainable and renewable biomass for 
production  of  bio-based  products  as  an  example  where  the  EU  could  allocate  funds  for 
innovation. 

Businesses called for an EU harmonisation of end-of-waste criteria to facilitate the recycling 
of  materials  and  facilitate  compliance  with  product  legislation.  In  general,  they  defended  a 
holistic  and  balanced  approach  on  circular  economy,  resource  efficiency  and  chemical 

13 

 
 
content in products to increase recycling, including research on options for decontamination 
of waste streams and chemical recycling. Some businesses expressed the view that recycling 
should  be  prioritised  and  that  it  should  be  part  of  the  risk  assessments  of  chemicals. 
Businesses  provided  conflicting  views  regarding  information  on  chemicals  in  recycled 
material,  some  of  them  considering  it  essential  for  enhancing  the  EU  market  for  secondary 
raw materials, while others believing that full tracking is not feasible. They generally called 
for avoidance of substances of concern in the design phase and employing a holistic approach 
also considering circular economy and resource efficiency in a robust eco-design policy. 

NGOs  asked  to  introduce  broad  restrictions  with  reduced  possibilities  for  derogations  for 
recycled materials. They also suggested that substances of concern should be eliminated from 
the  production  of  virgin  materials  and  products  to  avoid  their  presence  in  waste,  while 
strongly advocating for equal requirements for recycled and virgin materials under chemical 
legislation.  

3.3.3.  Strategic autonomy 

In  view  of  the  COVID-19  crisis,  there  was  generalised  support  for  the  idea  of  increased 
autonomy of the Union regarding the production of certain essential chemicals. The role of 
certain  chemicals  in  the  protection  of  human  health  was  also  highlighted.  However,  many 
stakeholders considered it necessary to ensure that such autonomy is based on sustainability 
and respects the environmental objectives of the Union. 

Businesses  were  especially  keen  on  supporting  actions  to  increase  production  in  the  EU, 
including  repatriation  of  chemical  production.  They  considered  that  there  is  a  need  to 
strengthen  Europe  as  a  location  for  chemical  production.  NGOs  found  it  important  that 
decreasing dependency  of imports and achieving industrial autonomy for essential products 
go  hand  in  hand  with  reducing  pollution  and  strengthening  the  potential  to  develop  safer 
solutions and replacing hazardous chemicals.  

3.3.4.  Post COVID-19 recovery 

Stakeholders welcomed the idea of contributing to the recovery of the industry producing and 
using chemicals after the crisis, seeing it as an opportunity for the overall transition to a more 
sustainable  sector.  Many  respondents  highlighted  the  importance  of  competitiveness  and 
innovation  to  ensure  that  the  environmental  and  climate  objectives  of  the  Commission  are 
achieved.  

Businesses considered that the COVID-19 crisis has demonstrated the global interconnection 
of  the  chemicals  supply  chain,  which  emphasises  the  need  for  global  standards  and  greater 
EU independence. Some businesses considered that the location and relocation of industries 
in Europe is not attractive to companies due to the high regulatory burden of registration and 
approval  of  pharmaceuticals  and  biocides.  Some  respondents  favoured  the  introduction  of 
specific funding for the recovery and transition of the chemicals sector, and others in addition 
proposed  the  development  of  a  system  similar  to  the  carbon  border  adjustment  in  order  to 
decrease the import of SVHCs in products. 

14 

 
 
3.4.  SIMPLIFICATION OF THE LEGAL FRAMEWORK 

The importance of increasing coherence and simplifying the legal framework was stressed in 
many  contributions.  Among  the  main  issues  identified,  stakeholders  mentioned  the 
importance to have the same rules for imported and EU produced articles, to improve certain 
processes  (for  example,  authorisation  under  REACH),  to  reduce  administrative  burdens,  to 
establish stronger links between different EU chemical legislations and to increase synergies 
with  other  political  priorities.  The  objectives  of  the  Strategy  were  strongly  supported, 
particularly  the  idea  of  advancing  towards  a  ‘one  substance,  one  assessment’  approach  and 
improving enforcement of existing legislation. 

Some  public  authorities  stressed  that  a  long-term  sustainable  funding  and  resourcing  of 
ECHA should be secured corresponding to the activity level required, e.g. by establishing an 
annual  fee  for  registrants.  They  also  considered  that  the  interface  between  REACH  and 
Occupational  Safety  and  Health  legislation  needs  clarification  with  the  aim  to  improve 
protection of workers from exposure to hazardous chemicals. 

Several businesses were of the view that risks relating to occupational use of chemicals are 
better addressed under the Occupational Safety and Health legislation than under the REACH 
authorisation  provisions;  therefore,  the  interface  between  these  two  pieces  of  legislation 
should be clarified and more binding occupational exposure limits should be adopted. Some 
businesses  emphasised  that  REACH  and  the  RoHS  directive  should  remain  separate,  but 
acknowledged that the RoHS process could be improved by drawing on different aspects of 
the REACH authorisation system. 

NGOs pointed at the inconsistencies of the regulatory framework for chemicals in products 
and defended a new focus on vulnerable groups while agreeing that simplification should not 
come at the detriment of the level of protection. 

3.4.1.  One substance, one assessment 

Stakeholders from all user groups supported a 'one substance, one assessment' approach, with 
businesses  calling  for  it  to  be  based  on  the  strongest  possible  scientific  data.  Public 
authorities  supported  the  establishment  of  a  network  of  European  agencies  to  carry  out 
independent studies of potentially hazardous substances through a single evaluation platform. 
Some Member States considered that in order to ensure a consistent hazard identification, this 
process  should be separated from  regulation  of the uses and that the CLP  is  an appropriate 
tool for that, adding new hazard categories. Public authorities supported the ’one substance, 
one assessment’ approach but mentioned that this requires access to reliable data on uses of 
chemicals  and  the  likely  exposures  to  them.  Furthermore,  the  implementation  of  the  ’one 
substance,  one  assessment’  approach  should  not  lead  to  lower  protection  standards,  but  to 
better protection of vulnerable groups, which should be defined.  

Businesses  also  called  for  a  harmonised  method  for  assessing  substance  properties, 
welcoming  the  ’one  substance,  one  assessment’  approach.  They  suggested  limiting  it  to 
hazard  assessment  and  that  the  strengths  of  the  various  EU  agencies  should  be  considered 
with ECHA taking care of hazard assessment, while other agencies or scientific bodies should 

15 

 
 
conduct  exposure  and  risk  assessments  within  their  specific  remit  and  expertise.  Grouping 
assessment could  be promoted, in  the opinion  of some businesses, based on the established 
read-across assessment framework. The use of alternative methods for filling data gaps needs 
to  be  accelerated  for  reducing  the  dependence  of  animal  testing.  Businesses  strongly 
advocated for the development of mandatory regulatory management option analyses before 
developing proposals for regulation of chemicals and that proposals should be accompanied 
by robust impact assessment or risk-benefit analysis.  

NGOs  suggested  that  the  ’one  substance,  one  assessment’  should  include  all  available 
evidence, including studies from academia and independent scientists; and that the use should 
not lead to delays in regulating harmful chemicals, nor lower the protection level. They also 
supported  allowing  the  use  of  grouping  approaches  for  assessing  and  regulating  chemicals 
and defended that, when there is scientific uncertainty, the precautionary principle should be 
used.  Animal  welfare  NGOs  considered  that  existing  barriers  to  the  use  and  acceptance  of 
non-animal  methods  for  regulatory  purposes  should  be  addressed,  and  that  the  use  and 
acceptance  of  exposure-based  waivers  for  adaptation  should  be  increased.  Academia 
supported  the  ’one  substance,  one  assessment’  approach,  mentioning  that  the  scope  of  the 
approach  needs  to  be  further  identified,  for  example,  whether  it  is  restricted  to  hazard 
assessment or risk assessment covering the whole lifecycle.  

3.4.2.  A more simplified, coherent and predictable approach to manage risks 

Respondents mainly provided their views on simplification and predictability in relation with 
the REACH and CLP Regulations.  Chemical risk management was one of the areas where 
stakeholders  showed  more  divergence  in  opinions.  While  some  groups  defended  extending 
protection  for  certain  vulnerable  groups,  others  considered  the  current  approach  to  risk 
management fit for purpose.  

Public  authorities  providing  views,  supported  simplification  and  strengthening  of  the 
chemicals  acquis  building  on  the  precautionary  principle  and  better  protecting  citizens,  in 
particular  vulnerable  groups.  In  their  opinion,  the  REACH  instruments,  particularly 
restriction and authorisation, should be more balanced and effective in eliminating substances 
of concern, especially by assessing groups of substances and restricting all but essential uses. 
New hazard classes should be introduced in the CLP Regulation for endocrine disruptors, for 
persistent,  bioaccumulative  and  toxic  substances  and  for  very  persistent  and  very 
bioaccumulative substances.  

Businesses recognised REACH as the backbone of chemicals legislation and emphasised the 
need  for  a  stable  regulatory  environment  employing  a  risk-based  approach  for  an  effective 
and  proportionate  risk  management.  The  wider  sustainability  impacts  (climate,  circularity) 
should be taken into account in selection of risk management measures. The procedures for 
deciding on authorisation applications under REACH could be streamlined by postponing the 
deadlines for application giving more time to phasing out the use instead of having to apply 
for  authorisation.  Finally,  most  businesses  emphasised  that  the  CLP  Regulation  should 
remain aligned with the UN Globally Harmonized System of Classification and Labelling of 
Chemicals (GHS) and new hazard classes should be first introduced in the UN GHS. 

16 

 
 
NGOs  called  for  exempting  only  essential  uses  from  restrictions  under  REACH.  They  also 
defended  speeding  up  the  identification  and  phasing  out  substances  of  concern,  including 
SVHCs,  and  include  more  hazard  classes  as  SVHCs.  NGOs  strongly  supported  the  use  of 
generic approaches to risk management to ensure coherent application and protection across 
EU legislation for critical hazard categories. Animal welfare NGOs supported using exposure 
assessment  and  biomonitoring  for  protecting  human  and  environmental  health  instead  of 
excessive  animal  testing.  Academia  considered  that  the  current  limitations  of  the  socio-
economic  analyses  must  be  recognised, 
in  particular  as  regards  assessing  future 
environmental costs, impact on ecosystem services and resilience of ecosystems.  

3.4.3.  Zero tolerance for non-compliance 

Almost  all  stakeholders  from  all  groups  shared  similar  views  with  regard  to  enforcement, 
considering that strengthening it, particularly at borders, is a key element to ensure the proper 
implementation of EU chemicals legislation.  

Public  authorities  considered  that  sufficient  resources  should  be  allocated  for  enforcement 
activities and that this should be homogenous across legislation. Some Member States were 
in favour of the creation of a European control force with legal means for imposing sanctions, 
including control of e-commerce. Public authorities also considered that the import of goods 
not compliant with EU standards should be prevented. Businesses called for urgent action on 
enforcement  in  order  to  ensure  a  level  playing  field  and  avoid  unfair  competition  from 
incompliant  imports.  NGOs  also  supported  better  enforcement,  including  through  the 
strengthening  of  the  ‘no  data,  no  market’  provisions,  harmonised  sanctions  for  non-
compliance and increased access to information and participation from consumers. 

3.5.  KNOWLEDGE BASE 

Stakeholders  in  general  considered  it  important  to  address  existing  knowledge  gaps  on 
chemicals,  as  well  as  to  improve  access  to  and  sharing  of  existing  data.  Some  respondents 
considered  it  necessary  to  centralise  more  data  on  chemicals,  while  the  transition  towards 
non-animal testing was strongly supported by certain stakeholders from academia and NGOs.  

3.5.1.  Improved access to and sharing of data 

Stakeholders focused their attention on issues such as the tracking of chemicals through the 
lifecycle  of  materials  and  products,  the  inclusion  of  polymers  in  the  existing  registration 
scheme under REACH, the use of animals for testing, the communication of information on 
SVHCs  through  supply  chains  and  the  data  requirements  for  registration  of  chemicals 
produced in low tonnage under REACH. 

Public  authorities  suggested  making  easily  available  information  on  data  profiles  and  dates 
for expected update of registration dossiers available on the ECHA website; and registering 
potential hazardous polymers. They also supported the introduction of a lifecycle traceability 
system of substances of concern in materials and products that can also provide information 
to waste operators. Along with this, they supported the development of product passports and 
tools  for  consumers  to  be  informed  about  the  presence  of  SVHCs  and  other  chemicals  in 
products.  They  considered  it  essential  that  REACH  registrations  are  compliant  to  ensure  a 

17 

 
 
level  playing  field  and  that  a  transparent  and  solid  basis  is  available  for  chemicals 
management.  Some  Member  States  mentioned  that  a  mandatory  regular  update  of  dossiers 
should  be  required  and  non-compliance  should  lead  to  revocation  of  registration  numbers. 
The  REACH  evaluation  procedures  should  be  more  efficient  and  all  hazards  should  be 
clarified under substance evaluation to improve subsequent risk management. 

Businesses considered that the use of labels for communication to consumers is complicated 
and  that  communication  on  hazards  and  safe  use  of  chemicals  can  take  advantage  of  new 
digital technologies. Some mentioned that supply chain communication should be improved 
to collect and make available relevant data for risk assessment and selection of adequate risk 
management measures. Waste managers and recyclers emphasised transparency on chemicals 
in materials for sustainable recycling, while other businesses emphasised that information on 
the presence of a chemical does not imply knowledge on related risks. 

NGOs  advocated  full  chemical  transparency  in  supply  chains  and  towards  consumers  and 
workers,  including  by  strengthening  the  obligations  in  Articles  7  and  33  of  REACH. 
According  to  them,  safety  testing  of  chemicals  should  be  carried  out  by  independent 
laboratories.  Animal  welfare  NGOs  called  for  modern  approaches  for  assessing  and 
managing  the  potential  toxicity  of  chemicals;  and  to  incorporate  validated  non-animal 
methods  in  the  information  requirements.  Academia  supported  traceability  of  chemicals 
along  the  supply  chains  and  that  consumers  should  be  informed  so  that  they  can  make 
informed purchasing decisions. 

3.5.2.  Science-policy interface 

There was extended criticism among businesses and part of academia regarding the way the 
Roadmap referred to the Eurostat indicator on the production and consumption of hazardous 
chemicals,  which  they  considered  misleading  as  it  was  giving  the  false  impression  that  the 
hazardousness  of  chemicals  corresponds  to  a  risk  for  people  and  the  environment.  Other 
stakeholders focused on issues such as biomonitoring and early warning systems for chemical 
threats.  

Public  authorities  suggested  that  research  and  problem-driven  monitoring  of  effects  of 
chemicals  should  be  developed  and  linked  to  green  and  sustainable  substitution;  and  that 
research on the effects of chemicals on species, biodiversity, ecosystem resilience and impact 
of  climate  change  is  required.  The  development  of  suitable  indicators  for  measuring  the 
impact  of  chemicals  on  health  and  the  environment  is  also  needed,  in  their  view. 
Furthermore,  they  supported  the  development  of  an  early  warning  system  to  identify  new 
emerging chemical risks fuelled by data from multiple sources.  

NGOs  supported  better  early  warning  approaches.  Animal  welfare  NGOs  called  for  urgent 
investment in next generation, animal-free approaches. 

Academia called for increased involvement of scientists from universities in the development 
of  new  methods,  in  particular  testing  and  assessment  methods.  The  current  proposal  for  a 
candidate  Partnership  for  the  Assessment  of  the  Risk  from  Chemicals  was  seen  as  an 
important opportunity for increased collaboration. 

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3.6.  GLOBAL SOUND MANAGEMENT OF CHEMICALS 

Stakeholders agreed to consider global governance as important to avoid different regulatory 
requirements among countries. Some respondents called for the Commission to promote high 
European standards internationally and ensure fair competition  between European  and non-
European players.  

3.6.1.  International leadership 

Public authorities considered that the EU should actively contribute to international activities 
to achieve a holistic approach to the sound management of chemicals and waste. The Union 
should  contribute  to  a  more  sustainable  global  products  policy  and  promote  the  highest 
international standards related to health and the environment. 

Businesses  emphasised  the  need  for  a  coherent  implementation  of  the  UN  GHS  and  for 
support  to  the  development  of  the  Strategic  Approach  to  International  Chemicals 
Management  (SAICM)  as  a  foundation  for  sustainable  chemicals  management  and 
emphasised the value of the chemical industry’s Responsible Care programme.  

NGOs  supported  promoting  an  ambitious  international  framework  as  successor  to  SAICM 
with  roadmaps,  targets,  milestones  and  indicators.  They  also  suggested  rapidly  listing 
brominated  dioxins  under  the  Stockholm  Convention  and  withdrawing  all  existing 
exemptions  for  substances  under  the  convention,  as  well  as  strengthening  the  Minamata 
Convention. 

3.6.2.  Promoting standards outside the EU 

Public  authorities  favoured  adequate  measures  to  prevent  both  imports  and  exports  of 
chemicals banned or severely restricted in the EU in order to achieve a level playing field and 
a high level of protection. In this regard, the Strategy should aim to address or restrict import 
of  articles  produced  using  non-authorised  chemicals  into  the  EU.  Furthermore,  ambitious 
standards should be promoted at international level to ensure safe management of chemicals 
and preserve European competitiveness.  

Businesses  suggested  that  in  order  to  safeguard  innovation,  the  introduction  of  an  SVHC 
border adjustment mechanism could be investigated to promote greener technologies outside 
the EU. This would reward investors by ensuring a level playing field. 

NGOs suggested promoting the highest standards for the protection of human health and the 
environment globally and ensuring that REACH provisions apply to exported products. They 
also defended avoiding double standards. 

3.6.3.  Cooperation with third countries 

Businesses  suggested  that  the  Strategy  should  support  capacity  building  for  chemical 
management  (infrastructure,  know-how)  outside  the  EU,  in  particular  in  emerging  regions. 
This  could  be  achieved  through  cooperation,  sharing  of  best-practices  and  providing  tools 
(e.g. the International Council of Chemicals Association Toolbox). 

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NGOs  suggested  supporting  the  implementation  of  the  legislation  based  on  REACH  in 
developing countries and countries with economies in transition. 

4.  SUMMARY AND CONCLUSIONS 

Overall,  citizens  and  stakeholders  expressed  very  strong  support  for  the  preparation  of  the 
Chemicals Strategy for Sustainability. They considered the chemicals sector as an important 
part of the European economy that should be transformed and protected, and the chemicals 
legislation as a comprehensive set of rules that needs to be adapted to new challenges while 
ensuring  high  levels  of  protection  of  health  and  the  environment  as  well  as  the 
competitiveness of the European industry. 

There  was  a  general  agreement  on  the  need  and  scope  of  certain  actions,  including  the 
horizontal  identification  of  endocrine  disruptors;  the  definition  of  ‘safe  and  sustainable  by 
design’  criteria;  the  transition  towards  non-toxic  material  cycles;  introducing  the  ‘One 
Substance,  One  Assessment’  approach;  the  use  of  alternative  non-animal  studies  and 
scientific publications; the need for more  coherence between different  pieces of legislation; 
the  improvement  of  enforcement  at  EU  level,  including  the  import  of  products;  the 
introduction of traceability systems for substances of concern and an early warning system to 
identify new emerging chemical risks; and an increased international dimension for the Union 
on chemicals. 

Nevertheless, there was also diversity of positions regarding other issues, such as the need to 
include  biocides  and  pesticides  in  the  scope  of  the  Strategy;  the  scope  of  restrictions  on 
endocrine  disruptors;  the  approach  to  address  combination  effects  of  mixtures  and  use  of  a 
mixture assessment factor; the possibility of providing derogations in restrictions for recycled 
materials  containing  legacy  substances;  the  scope  of  the  ‘one  substance,  one  assessment’ 
approach  and  the  use  of  various  risk  assessment  approaches  under  different  pieces  of 
legislation; and the establishment of mandatory regulatory management options analyses. 

The feedback provided on the Commission roadmap for the Strategy has been used to inform 
policy-making and to develop concrete actions in the Chemicals Strategy for Sustainability.  

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