Europe is the second biggest producer of chemicals in the world, accounting for 16.9% of global sales. Chemical manufacturing is the fourth largest industry in the EU with 30,000 companies (95% of which are SMEs) and employs 1.2 million people directly and 3.6 indirectly.
Cities and regions deem it necessary to establish a coherent and simplified legal framework for the chemicals sector to make the industry greener and more effective. The European Committee of the Regions' (CoR) opinion on Safe and sustainable chemicals for a toxin-free environment in Europe's cities and regions recognises the importance of the new chemicals strategy presented by the European Commission and welcomes the steps leading to its implementation. The CoR calls for the full involvement of local and regional authorities considering their local market knowledge, their capacity to assess implementation on the ground and the specificities of each territory.
Our EPP-CoR member and rapporteur Adam Struzik, President of the Mazovia Region replied to a few of our questions:
1) What is the role of the chemicals strategy in the European Green Deal? Why is the local and regional dimension important in this context?
The Chemicals Sustainability Strategy for a Non-Toxic Environment, presented by the European Commission on October 14, 2020, is a long-awaited step towards achieving zero emission for a hazardous substance-free environment. It outlines a long-term vision of the EU chemicals policy consistent with the European Green Deal.
The strategy is an important element of economic policy, the priority of which are pro-ecological solutions in line with the European Green Deal. This is because the strategy puts emphasis on the protection of the environment and human health, and also stresses the need for innovation support in the field of safe and sustainable chemicals. We are aware that the implementation of the strategy will be a great challenge for consumers, the chemical industry and also for the regions. Local and regional authorities, as those closest to residents, are able to quickly and specifically identify problems that residents and businesses have to face, and then react.
These can be specific actions within competences of individual local authorities or reporting of possible comments in the applicable legislation. We are a tool that will enable to transfer of this information to national and EU authorities. Therefore, it is important to conduct a joint dialogue with local and regional authorities at each stage of implementation the provisions of the strategy and working on implementing acts and guidelines. The European regions, if they have financial possibilities, will be able to support the processes of implementing the strategy and will stimulate its particular areas, including innovation, research and development.
2) What is the role of the chemical strategy in the green recovery of the European economy?
What aspects of chemicals policy are affected by COVID-19?
Chemical strategy plays an important role in the ecological recovery of the European economy. The COVID-19 pandemic has highlighted dependence of EU countries, in particular on supplies from outside the Community. Therefore, one of the objectives of the Union is to strengthen the Community's autonomy in this area by creating resilient value chains. These activities are essential to ensure the availability of chemicals used in production processes, including pharmaceuticals, and to achieve the European Green Deal goals that is climate neutrality and zero pollution.
Determining the life cycle of materials and products will also be of great importance for the development of the European economy.
The COVID-19 pandemic has shown how important it is to replace currently used substances with completely new materials, including seemingly unused ones, such as recyclates. The so-called "Clearing the waste stream" has a completely new meaning in the current situation. The use of recyclates will affect the development of innovative technologies and will reduce the consumption of raw materials, minimizing the amount of waste generated. Therefore, the information on the chemicals composition and safe use of the products should be available.
3) Does the EU need to reform its chemicals regulations? If so, what are the most important aspects from a local and regional perspective?
The European Union has a comprehensive legal framework regarding chemicals. You can mention, among others Regulation on Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), Regulation on Classification, Labeling and Packaging of Substances and Mixtures (CLP), regulations on the safety of toys, cosmetics, biocides, plant protection products, food, carcinogens in the workplace and environmental regulations.
However, further action by Member States requires a strengthening of the legal framework in order to react rapidly to research results and to develop innovative technologies for safe and sustainable chemicals. In addition, a review of the REACH and CLP Regulations is to be expected, and procedures simplification, I hope. The new rules should complement existing law and make it more effective in application and enforcement through established and well-functioning processes. These activities should include, first of all, the protection of human health and the state of the environment.
4) What is the role of local and regional authorities in implementing EU chemicals legislation?
What are the main challenges and how to meet them?
Each implementation of new processes or solutions requires support and commitment from local and regional authorities. As I have already mentioned, these authorities know best the problems of their communities, including those related to the interpretation and implementation of legal regulations. What they already point out to is the need to take into account the time needed to adapt/transform installations and to manage hazardous chemicals withdrawn from the EU market, while ensuring competitiveness on the European and global markets. These activities’ aim is to ensure a sustainable transformation capable of fostering social and economic cohesion.
The implementation of comprehensive legal regulations for the chemical industry will provide local and regional authorities with the tools to effectively enforce legal regulations in a transparent way. Coherent and simplified legal regulations covering the EU market will affect an uniform and coordinated policy, and will also ensure the so-called "Equality before the law". The latter is particularly relevant in the context of importing safe chemicals from non-EU countries and ensuring the competitiveness of European markets.
Monitoring and reporting changes introduced in legal regulations will be a very important element. On this basis, local and regional authorities will be able to react and control compliance with them, as well as they will be able to obtain feedback on difficulties and problems related to the implementation and application of the introduced changes, and thus implement remedial actions.
5) What is the relationship between chemicals and the circular economy?
The circular economy is a very broad topic that covers basically the entire area of thinking about the economy as such, and the issue of chemicals is one of the most determining factors in any production and is inevitably closely related to the economic area and affects it. So it is enough, while dealing with chemistry, to think about its potential and possibilities of endless processing and usefulness in various processes and we immediately have a ready relationship between both. An example can be the so-called "Clearing the waste stream" and increasing the use of recyclates.
However, attention should be paid to the content of potentially hazardous substances in recycled products and materials. It is important that they are a safe raw material of further production. Therefore, the strategy emphasizes the need to provide information on the chemical composition of the products, as well as the use of a product sustainability assessment, which should pay attention to its full life cycle.
Chemical recycling is an opportunity for the chemical sector, as it reduces the impact on the environment and introduces innovative solutions enabling the use of recyclates in products, as well as enabling the production of high-quality recyclable materials.
6) You consulted a number of stakeholders to prepare this opinion. What are the most important aspects of their opinion?
The opinion: "Safe and sustainable chemicals for a toxin-free environment in European cities and regions" was adopted at the plenary session of the European Committee of the Regions on May 6, 2021. As part of the work on the opinion on the Chemical Strategy, a number of meetings and consultations with stakeholders were held, including local governments, non-governmental organizations, science and business circles and the chemical industry.
At the stage of drafting the document and its consultations, numerous comments and conclusions were submitted, raising important issues for individual authorities, regions and industries. The activities undertaken allowed to shape the opinion on the Chemical Strategy in its current form, including a wide range of topics and issues, as well as indicating both the advantages and benefits of the activities carried out, as well as the threats that both regional and local authorities, residents and industry will have to face.
One of the most important issues raised during the consultation was the necessity to do a legislative review. This is related to the need to simplify and standardize the legal framework, which will allow for a uniform approach to the assessment and management of chemicals in all EU countries. This will also contribute to ensuring the transparency of their application and the effectiveness of their enforcement. Enforcement of uniform requirements and rules by relevant authorities in all Member States will be of great importance for the competitiveness of European companies in the context of importing products from outside the EU and the protection of confidential business data.
Another issue was related to assurance of financial and technical security that enables the implementation of the Chemical Strategy assumptions. These activities are aimed at promoting research and supporting investment in sustainable chemicals and technological innovation. When implementing the provisions of the strategy, it is very important to cooperate and exchange knowledge between scientists, entrepreneurs and regions in order to improve technology / law and to develop an environmentally friendly economy.
Moreover, the chemical transformation of enterprises is an integral part of achieving the objectives of the Chemical Strategy. However, it is important to implement the provisions of the document in a rational and thoughtful way, taking into account, among others, time needed to adapt / convert installations, as well as to educate employees in chemical management. An important issue, both in terms of financial issues and environmental costs, is also the management of waste generated in connection with the withdrawal of some substances / products from the EU market. Therefore, it is very important to create innovative solutions that guarantee the treatment of waste streams, the recycling increase and limitation of landfilling waste, especially plastics and textiles.