On March 15th, the Council of the European Union adopted the new EU chemicals strategy for a toxic-free environment, advising the European Commission and the Member States to “fully implement the Chemicals Strategy, within their powers, without undue delay”. The Strategy puts in place a long-term vision for the EU chemicals policy aiming to achieve a high level of protection of human health and the environment.
Ecopreneur.eu welcomes the Council’s conclusions, as they are widely in line with our response to European lawmakers in 2018.
The European Council “stresses the importance of the safe and sustainable-by-design approach in the context of a life cycle approach to chemicals, from the raw materials used for production to the waste stage”. The Strategy will contribute to strengthening the competitiveness of the European industry through the production and use of safe and sustainable chemicals that “enable the green and digital transitions by substituting and minimising substances of concern, as far as possible”, and phasing out the most harmful chemicals for non-essential societal uses.
However, in our initial response, Ecopreneur.eu emphasized the importance of a second impact assessment at the end of the policy-making process to prevent disproportionate, unnecessary and unfair competitive disadvantages from new EU legislation for small and medium size enterprises (SMEs), – a measure that is missing in the final Strategy.
In order to identify both positive and negative social and environmental impacts along the value chain, we also advocate for a mandatory gate-to-gate life cycle analysis for all companies to perform as part of their risk management.
A third element we are missing in the Council’s conclusions is a statement on chemical recycling, which, in our opinion, should only be funded using EU subsidies if run on renewable energy or at least result in a net CO2 emission reduction compared to virgin production. This is part of ongoing negotiations whether or not chemical recycling technologies would be qualified for green investment under the new EU Taxonomy.