What is the Chemical Strategy for Sustainability? Why is it needed and what are its goals?
The European Commission published the Chemicals Strategy for Sustainability on October 14, 2020. It is part of the EU’s Zero Pollution Action Plan, which is a key component of the European Green Deal. The Commission states that the CSS “strives for a toxic-free environment, where chemicals are produced and used in a way that maximizes their contribution to society, including achieving the green and digital transition, while avoiding harm to the planet and to current and future generations.”
The CSS aims to better protect citizens and the environment as well as to boost innovation for safe and sustainable chemicals. Some concrete actions it recommends include:
Banning the most harmful chemicals in consumer products, allowing their use only where essential
Phasing out the use of per- and polyfluoroalkyl substances (PFAS) in the EU, unless their use is essential
Establishing a simpler “one substance, one assessment” process for the risk assessment of chemicals
The CSS also identifies initiatives to support the green and digital transition, including the promotion of toxic-free material cycles and “clean” recycling to ensure that substances of concern in products and recycled materials are minimized.
What will happen as a result of CSS?
The Chemicals Strategy for Sustainability will address five major topics:
It will introduce the Safe and Sustainable by Design concept and encourage industry to innovate towards non-toxic materials and innovative processes.
It will introduce a stronger EU legal framework to address environmental and health concerns.
It will simplify and consolidate the current legal framework by introducing the “one substance, one assessment” concept as well as a zero tolerance for non-compliance principle.
It will develop a comprehensive knowledge base on chemicals with specific information requirements across the value chain.
It will play a leading role globally by championing and promoting high chemical safety standards and not exporting chemicals banned in the EU.
To deliver these changes, the REACH and CLP (Classification, Labeling, and Packaging) regulations will be revised. These revisions will make it easier for EU authorities to evaluate and restrict larger groups of chemicals that do not meet the EU’s standards for acceptable risk, which are based on the precautionary principle approach.
Accordingly, chemicals of concern, such as endocrine-disrupting, persistent, mobile, and bioaccumulative substances, will likely face restrictions following the revision of REACH and CLP.
What are we doing to accommodate CSS now?
Discussions around how the CSS will be implemented are complex and ongoing. This makes it challenging for companies that are ready to start implementing internal changes, like Avery Dennison, to adapt to forthcoming requirements and deliver safe and sustainable solutions to the market.
To track the progress of CSS, we rely on our Government Affairs function, which closely follows discussions in Brussels between stakeholders from European industry, professional associations, NGOs, and national authorities on how the CSS can be made a success, while also safeguarding competitiveness.
Relevant developments are swiftly communicated to our internal functions. This ensures that key functions, such as R&D, have all the information they need to make strategic decisions about our innovation efforts. Meanwhile, our Global Compliance team regularly provides updates and guidance to our customers to ensure they are on top of the latest developments.
How are we preparing for the future?
Despite the above challenges, because we are committed to our ambitious sustainability goals, we are taking a proactive approach to CSS. Our general approach is to phase out chemicals of concern from our product portfolio prior to deadlines specified by the legislation.
When it comes to the development and design of all of our new products, we apply EcoDesign principles and follow a close auditing process related to CSS. We have also implemented a go-no go principle. This means that we only work with chemicals slated for potential regulation through CSS on an exceptional basis, and if no alternative is available, we need to develop a future project which accommodates the ban of the chemical.
To effectively and thoroughly address the impact of CSS, we have created an interdisciplinary and interdepartmental CSS team. They are working together to identify all chemicals we use in our products, create road maps to substitute chemicals of concern, and develop alternative products.
We are also taking the needs of our global teams into account - and driving positive change in our operations outside of Europe - via our Global Compliance team.