Cefic Statement On The Publication Of The EU Recommendation Establishing An Assessment Framework For ‘Safe And Sustainable By Design’ Chemicals And Materials

The EU chemical industry has been recently spending more than € 9 billion on research & innovation annually and is constantly inventing new materials and products. Advanced materials developed by the chemical industry are already making the EU green transition possible. The Safe-and-Sustainable-by-Design framework can become a global reference for safe and sustainable innovation and an additional catalyst for our industry to transform towards the 2050 goals. The next  – and more crucial –  step will be to ensure that this Recommendation could accelerate innovation in practice.

In particular, the EU chemical industry would like to further work with the European Commission on the following aspects of the framework to make it feasible for industry to integrate the framework existing R&D procedures and practices:

(*) The framework puts a lot of emphasis on safety assessment. However, guidance on equally important other aspects such as circularity, broader sustainability or socio-economic considerations is not fully developed yet.

(*) Instead of introducing a concept of “cut-off/exclusion” criteria for substances, a more nuanced and innovation-friendly approach would be to use a scoring system to highlight innovation improvements and flag further development needs.  Differentiation in use of the chemical or material could then be captured in such a scoring system.

(*) Companies will need to generate a lot of new data when following this framework. On the one hand, it is a positive development since it will help develop a lot of FAIR (Findable, Accessible, Interoperable, and Reusable) data to accelerate innovation process. On the other hand, it adds additional reporting requirements on businesses, including SMEs, which will require extra resources and capacity.

Cefic and its members will continue engaging with all stakeholders on this topic to support the testing period and share feedback on the applicability of this framework in practice.  In particular, we will do this via two major EU initiatives launched to accelerate transition to safe-and-sustainable materials, products and processes – IRISS and PARC (the European Partnership for the Assessment of Risks from Chemicals). 

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