Definition of 'Essential Use': Alliance for Sustainable Management of Chemical Risk (ASMoR) urges clarity

The Alliance for Sustainable Management of Chemical Risk (ASMoR) has expressed its concerns regarding the lack of a conclusive definition of the term "essential" in the recently published report "Supporting the Commission in developing an essential use concept". The report discusses the concept of essential use in the context of chemical regulations but fails to provide a clear and comprehensive definition.

According to ASMoR, the report indirectly explains "essential" through two other elements: "critical for the functioning of society" and "necessary for health/safety." However, both of these elements are also undefined and discussed in a broad and inconsistent manner. ASMoR believes that the complexity surrounding the definition of "essential use" is one of the most critical outputs of the report.

ASMoR highlights the European Commission's commitment, outlined in the Chemicals Strategy for Sustainability (CSS), to develop criteria for essential uses that consider health, safety, and the criticality of a chemical for the functioning of society. However, ASMoR finds the CSS wording on health and safety relatively generic and limited to "severe health issues." ASMoR believes that a clear and transparent definition of "essential" is necessary for the EUC to encourage innovation in safe and sustainable alternatives to harmful chemicals.

In conclusion, ASMoR acknowledges the report's contribution to the discussion on "essential" but finds it too theoretical to serve as a basis for regulatory intervention. ASMoR emphasises the need for a thorough discussion process and refinement of the concepts included in the report to avoid potential harm to the EU's global competitiveness and innovation.

Read the full position paper: ASMoR considerations on the definition of “essential” in the WSP Essential Use Report

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ASMoR is an alliance comprising more than 30 members with a shared objective of preserving safe uses of hazardous substances through the implementation of the Essential Use Concept (EUC) in EU chemical legislation. Formed in response to the EU Chemicals Strategy for Sustainability, ASMoR addresses the practical application of the EUC and advocates for a balanced approach to chemical risk management.