Replacing harmful chemicals with safer alternatives and greener technologies is strongly driven by regulation, with companies reporting that restrictions and authorisation are their main drivers for substitution. Companies are also motivated by customer demand and their own sustainability policies, with ECHA’s substitution strategy also indirectly boosting substitution activities.
While restrictions and authorisation directly encourage European industry to substitute harmful chemicals, ECHA’s support for substitution has also played a role. ECHA’s two published reports uncover both the direct and indirect effects of REACH in driving substitution.
Based on a survey of industry associations and more than 80 companies, many of which were affected by authorisation or restriction, around 19 % indicated that restriction is their main reason for replacing hazardous chemicals with safer alternatives.
Adding a substance to the Candidate List or Authorisation List were the next most significant triggers for companies, with authorisation selected by 15 % of the companies responding. Some companies have reportedly substituted when a regulatory management option analysis (RMOA) was still under development, and especially when the assessing Member State had, following the outcome of the RMOA, proposed a further regulatory risk management activity, such as identification of substances of very high concern.
Aside from regulation, companies also highlighted demands from their customers, enhancing their public image and adopting their own corporate sustainability policies as their main drivers to substitute hazardous substances with safer alternatives.
“It’s clear that the most innovative companies are those that have adopted a green mindset, with substitution at the core of their business activities. While regulation pushes for harmful substances to be replaced, moving away from them is also increasingly becoming an essential part of their corporate policies and the way towards a sustainable and greener Europe in the future,” says Bjorn Hansen, ECHA’s Executive Director.
The report outlinesa combination oftechnical, economic and market barriers that companies face when substituting – including difficulties in finding technically-feasible alternatives, a lack of financial incentive and a reduced competitive advantage.Companies do, however,see decreases in worker exposure and emissions to the environment as the main benefits of substitution.
ECHA’s report onsubstitution-supporting activities with a focuson 2020-21describes how ECHA has helped and intends to help companies overcome these barriersby:
- promoting training on analyses of alternatives to build organisations’ capacity for informed substitution;
- supporting Member States and industry stakeholders to organise supply chain workshops addressing substances on the Candidate and Authorisation lists, those proposed for restriction, and for biocidal products containing substances that are suitable candidates for substitution;
- maintaining substitution-related networks and promoting the concept of safe-by-design to enhance knowledge sharing, communication and coordination among stakeholders in the EU on these topics; and
- contributing to the OECD’s work on a guidance on safer alternatives to further support the EU’s work on substitution, including on the broader concept of sustainability.
The progressive substitution of substances of very high concern (SVHCs) with suitable alternatives is one of three key objectives of the REACH authorisation title. The others are making sure that the risks to human health and the environment are properly controlled and ensuring the good functioning of the internal market.
When there is an unacceptable risk to human health or the environment, arising from the manufacture, use or placing on the market of substances, a restriction can be adopted.
Substitution also contributes to the overarching EU objectives for a non-toxic environment and a circular economy by progressively replacing harmful substances with more sustainable alternatives.
The first of ECHA’s new reports summarises the results of a survey on the impacts of REACH restriction and authorisation on substitution in the EU. This is complemented by another report on the implementation of ECHA’s substitution strategy in the past two years and what ECHA will focus on in 2020-21, in addition to regulatory risk management. The two reports aim to show how substitution is driven both by regulatory action and by encouraging companies in an indirect manner.