As a sector we want to meet the 2020 objectives for safe chemicals management. How can the EU achieve its sustainability objectives at the same time as safeguarding jobs and competitiveness? We explain here how policy-makers can get the balance right by targeting a risk-controlled Europe.
Our vision: a risk-controlled Europe
Speaking for the non-ferrous metals industry, we share the EU’s objective to minimise the problematic use of hazardous substances. We’ve been working together on this for over a decade, through REACH and other EU regulation.
However, we are concerned by some suggestions that the Non-Toxic Environment strategy should aim to eliminate all hazardous substances, without distinction.
Doing so would take essential metals out of the European economy, jeopardising jobs and competitiveness across the metals value chain. There has to be a more nuanced approach.
Why do we talk about a risk-controlled Europe? Because metals classified as hazardous are already used safely in more applications than you are probably aware of. One example is the stainless steel cutlery you ate with today, which is alloyed with nickel, chromium and cobalt. Those metals all have hazardous properties, but you have no issue earing with them because there is no risk of harmful exposure.
Hazardous metals can be used in ways that do not harm human health or the environment. We work together with EU regulators to define what those applications are, and to restrict the use of hazardous metals where the risk cannot be controlled.
Four areas to improve EU policy
To achieve our vision, we think there are a number of “win-win” ways to improve the EU’s existing legislation.
The European Commission is reviewing the REACH Regulation in 2017. Their review is an opportunity to take stock after 10 years of practical experience with chemicals management.
Upgrading the REACH Regulation will lead to more effective management of risks from the manufacturing and use of hazardous substances. Read our 5 recommendations here.
Industry datasets offer the most robust available information on non-ferrous metals. Too often, they are overlooked in other European and national legislation, leading to unfair stigmatisation and inconsistencies.
We encourage cooperation from authorities and industry to keep their REACH data state-of-the art, and to make sure it is used as the starting point for all risk assessments.
For many hazardous substances, various risk management measures can prevent unsafe exposure to humans or the environment. The EU should evaluate these measures thoroughly before resorting to a substance ban or restriction.
The REACH Regulation’s Risk Management Option analysis (RMOa) tool allows regulators and industry to review all possible measures, and their effectiveness in controlling risk. We recommend to give it legal standing as a requirement for all REACH substance assessments and elsewhere.
EU Chemicals and Circular Economy policies have specific focuses, which should complement each other.
To achieve a risk-controlled Europe, EU chemicals and Circular Economy policies should work coherently to keep materials in the loop, and to make sure they are handled safely across their full lifecycle.