Carbon Consulting Boenigk
CCB
Enhance communication between companies and industry associations with the European Commission and its central agencies to improve the understanding of manufacture and use of chemicals
ID: 685913332945-61
Lobbying Activity
Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
26 May 2021
Position on the initiative to revise the CLP-Regulation
The European Green Deal and the Chemicals Strategy for Sustainability develop to be the umbrella for a number of euphonic proposals lacking a tedious consideration of the consequences. The vision presented to bloat the CLP-Regulation is one of them.
Within two decades the European share of global chemical industry dropped from 30% to 15%. This coincides with the introduction of REACH and the Biocidal Products Directive/Regulation. Today, Europe is seen as the region with the most-advanced regulatory framework for chemicals in the world. The current CLP-revision proposals make believe that Europe now tries to go beyond the globally accepted classification rules (GHS) for chemicals, hoping that the others will follow. This may prove to be a disappointing experience and risks further jeopardising European chemical industry.
Many chemicals are no longer produced in Europe. One consequence is the unreliable availability of certain APIs (Active Pharmaceutical Ingredients). This shortage is caused by shifting production to India or China. Another example is the Biocidal Products Regulation. The number of active substances in use decreased significantly. In most cases phased-out biocides were not banned by the regulator, but were dropped by the manufacturer. The financial burden to uphold an authorisation is no longer allowing an adequate company profit. The trustful expectation of new healthy active chemical stars did not materialise. The introduction of a new chemical substance is a costly adventure in view of an unpredictable approval process.
The Commission aims at boosting innovation of safe and sustainable chemicals. This vision is worth having a closer look at. Chemical industry tends to use easily accessible building blocks that can be produced from large volume raw materials. The world of simple reactions of these building blocks is explored. This clearly means that innovative new chemicals will exhibit more complex structures. Due to their complexity they risk having more undiscovered unhealthy properties. They certainly will show a more complex degradation path to be taken into account before deciding whether these chemicals are really safer and more sustainable. Very likely “old” chemicals will be needed as intermediate building blocks for producing these more complex chemicals.
Overstretching the burden on European chemical industry risks driving more production units elsewhere. Others are looking forward to export more consumer products into Europe.
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