One key objective of the EU’s REACH authorization is the progressive substitution of substances of very high concern (SVHCs) with safer and greener alternatives.
ECHA has published two reports that uncover the direct and indirect effects of REACH in driving substitution: The first summarizes the results of a survey on the impacts of REACH restriction and authorization on substitution in the EU. The second looks at the implementation of ECHA’s substitution strategy in the past two years and what ECHA will focus on in 2020–21, in addition to regulatory risk management.
Substances that are placed on the Annex 14 list of REACH may not be used in the EU, unless a company (and their registered users) have been authorized to do so. Substances that qualify for consideration for authorization are known as SVHCs and are listed in the Candidate List.
According to the reports, companies report that restrictions and authorization are their main drivers for substitution. Companies are also motivated by customer demand and their own sustainability policies.
Based on a survey of industry associations and more than 80 companies, many of which were affected by authorization or restriction, around 19 % indicated that restriction is their main reason for replacing hazardous chemicals with safer alternatives.
Adding a substance to the Candidate List or Authorisation List were the next most significant triggers for companies, with authorization selected by 15 % of the companies responding. Some companies have reportedly substituted when a regulatory management option analysis (RMOA) was still under development, and especially when the assessing Member State had, following the outcome of the RMOA, proposed a further regulatory risk management activity, such as identification of substances of very high concern.
Aside from regulation, companies also highlighted demands from their customers, enhancing their public image, and adopting their own corporate sustainability policies as their main drivers to substitute hazardous substances with safer alternatives.
The report outlines a combination of technical, economic, and market barriers that companies face when substituting – including difficulties in finding technically-feasible alternatives, a lack of financial incentive, and a reduced competitive advantage. Companies do, however, see decreases in worker exposure and emissions to the environment as the main benefits of substitution.
- European Chemicals Agency (ECHA), Helsinki, Finland
- Impacts of REACH restriction and authorisation on substitution in the EU, ECHA 2020.
- Report on substitution-supporting activities in 2018-2019 and focus in 2020-21, ECHA 2020.