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Chemicals Strategy for Sustainability (CSS). Success or catastrophe?

The full title of this project, launched by the European Commission last October, is ‘Chemicals Strategy for Sustainability. Towards a Toxic-Free Environment’. This long and ambitious tirade in fact conceals a general overhaul of the chemicals strategy so as to adapt the existing legal frameworks and possibly add further tools if the need to do so is felt. When it was announced, the project seemed feasible, but…

The chemicals strategy is part of the "Green Deal", the main aim of which is to ensure climate neutrality in Europe by 2050. The implementation of the chemicals strategy, which comprises over 50 measures, will have significant consequences for the chemicals industry and those who use chemicals. Among other things, there are plans to modify and reinforce the REACh and CLP regulations. This involves in particular new and wide-ranging requirements as regards data, restrictions on use and the total regulation of substance groups with certain properties. New danger classes are also being integrated into the CLP regulation, a safety factor for blends and the concept of product essentiality. Overall, the legislation on chemicals as a whole will focus more on the dangers, rather than on the risks linked to concentrations in exposure scenarios. And yet, as Paracelsius said: “All things are poisons, for there is nothing without poisonous qualities. It is only the dose which makes a thing poison.”

And in that respect, the ‘revolution’ brought about by the REACh regulation (Registration, Evaluation, Authorisation of Chemicals) in the 2000s was life-saving. The previous legal framework did not achieve its aim of evaluating all chemicals. Now, thanks to REACh, everyone agrees that in about fifteen years European society has come to benefit from an unprecedented knowledge of chemicals. To achieve this result, the companies that produce substances as well as those that use them in blends to make finished products have invested as never before in compliance with the regulations. Teams and budgets have been expanded in order to integrate this complex regulatory framework and to pass information all along the supply chain, right as far as the end user, in a helpful manner.

The implementation of the chemicals strategy, which comprises over 50 measures, will have significant consequences for the chemicals industry

During the same ten-year period, the European legislator completed the exercise by adopting the CLP regulation (Classification, Labelling and Packaging), intended to convey all the knowledge compiled thanks to REACh. The application of the CLP regulation to professional and industrial products (i.e. products for which the end user generally receives more comprehensive support, in addition to the label) is definitely a step forward because this regulation enables informed trade with the whole world. However, the application of the same communication rules for products intended for the general public proved far less of a success. What average consumer is capable of deciphering the information and the pictograms on a CLP label? … Backed up by this experience, it is important to make sure that the implementation of the CSS resolves the failures observed, without creating other problems and above all, without losing sight of the real issue, which is sustainable development.

Innovation as a driving force

To clearly understand how this strategy should be implemented so as to ensure its long-term success, an unusual and daring approach needs to be adopted: the proper implementation of the CSS must be compared to the “gastronomy of dietetics”. It is well-known today that diets, based mainly on privation, without taking into account individual needs, always end up producing the opposite effect than the desired result. So nutritionists do their utmost to ensure that, even though it is the initial goal, slimming is not the only objective. In this case, they talk about learning to eat and drink again, to live a long life, in good health, etc. They apply the principles of the “gastronomy of dietetics”. Dietetics is the science of food hygiene. It is based on constantly evolving scientific and medical knowledge. Adopting a scientific approach avoids the pitfalls of “fashionable” diets, each more outlandish than the other. And then there is gastronomy, the art of choosing, cooking and eating good food. This complement to dietetics highlights the fact that it is important to take pleasure in eating well and that we always succeed better with things that we do with pleasure.

Let’s return to the CSS. If the “curists” are chemicals and safety for human health and the environment is the equivalent, of losing weight, then where is the pleasure in the CSS equation? In the innovation, of course. This is what will allow us to face the future with confidence, aiming for the constant improvement that is so dear to sustainable development. This is what will drive the chemicals industry and will be able to make this great project a success for several decades.

Now that the strategy has been launched, we will have to make sure that at every stage in its implementation, this pleasure is preserved.