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Product Stewardship

Advocacy for a risk-based and science-based approach to product safety

Product stewardship is about manufacturers and downstream users – companies or individual employees who use chemicals – committing to minimize the environmental, health and safety impacts of their products throughout the product life cycle, using a risk- and science-based approach. Actions range from substituting the most hazardous substances, to good safety communications on risk management measures to reduce exposure so products can be safely used in the manner intended.

In our modern, open economy, chemicals undergo a thorough risk assessment before reaching the market. Communication on safe use takes place throughout the supply chain via safety data sheets and product labels. Efficient enforcement ensures that products placed on the European Union market meet the highest EU product standards.

essenscia is actively cooperating with regulators and other sector players in developing and implementing a risk-based regulatory framework for product safety. The federation is working hand-in-hand with authorities such as the European Chemicals Agency (ECHA) to implement the ambitious legislation on hazard assessment & communication (CLP, Classification, Labelling and Packaging) and risk assessment & management (REACH, Registration, Evaluation, Authorization and Restriction of Chemicals). This requires relentless effort and a lifelong commitment, for example in terms of the quality and updating of data in the REACH registration dossiers in response to new scientific information and changing technical requirements.

The sharing of experience and best practice amongst all industry players for continuous improvement of implementation, especially towards SMEs, is handled through the essenscia VLARIP and WALRIP training programmes, recognised in 2018 with a European Responsible Care Award. It is a continuous effort and life-long commitment, for instance concerning the quality and updating of data in the REACH registration dossiers upon new scientific information and changing technical requirements. Since training is key to improving good practices of the members, especially SMEs, essenscia successfully passed recertification for the KMO-Portefeuille (a measure of the Flemish government).

Health and safety information is not only shared with direct customers through the CLP labels on products and safety data sheets, but also with authorities and consumers. essenscia’s product groups Detic and Phytofar are engaged in various programmes to better inform consumers as well. The dissemination of REACH registration hazard data and risk analysis on the ECHA website further increases transparency, not only within the supply chain but also to the general public. essenscia also has a partnership with the Belgian Poison Centre, a crucial organisation supporting citizens in the event of a chemicals-related incident.

The transition to a circular economy will require even more transparency, especially in relation to the presence of substances of potential concern in articles for adequate use and end-of-life management. essenscia is already actively involved in finding practical solutions to the challenge of providing the required information in an appropriate and efficient manner without creating administrative burdens nor jeopardising confidential business information.

Enforcement of the existing legislation on imported articles remains crucial not to import strictly regulated substances through finished articles, and thus exposing European consumers and the environment during use, waste and recycling stage. The safety Gate system (Rapid Alert Exchange System for dangerous non-food products) clearly demonstrates that more action is needed. In 2020, of the products reported due to presence of restricted chemicals (18% of the products reported), products not respecting the hazardous chemicals limits specified in REACH represent a total of 471 cases reported of which almost 80% of them come from outside EU/EAA, and due to on-line sales, the origin was unknown for 17% of them. Non-compliant toys (presence of restricted phthalates) and chemicals (especially non-compliant hand sanitizers which had a boost in production due to the COVID-19 crisis) make up the top 2 of 2020 non-compliant products related to chemicals legislation.

This data shows there is still clearly a need for enforcement on imported articles. The industry invests time and effort looking for alternatives, whilst restricted chemicals keep being imported in finished articles, exposing consumers and the environment. 

A new EU Market Surveillance Regulation and national coordination has to be put in place. It will monitor and coordinate Belgian efforts to enforce the more than 70 EU harmonised product legislations onto the Belgian territory. It should help to further improve the efficiency of Belgian enforcement efforts and increase transparency of the results to maintain consumer trust that products on the shelf in Belgium do in fact respect EU product rules. Special attention is needed for sales through online platforms. 

Also proactively, and in addition to regulatory requirements, actively screen product portfolios to steer them towards better overall sustainability performance and thus future-proofing portfolios, given the high demand – from several actors ranging from the European Commission, over financial actors, over consumers and business clients – for products that, rather than do no harm, actively contribute towards the United Nations Sustainable Development Goals. Those companies already joined forces in 2018 to develop a methodology, described in the report of the World Business Council on Sustainable Development publication on ‘Chemical Industry Methodology for Portfolio Sustainability Assessments (PSA)’.

Objective information in layman’s language is hard to find, which is why essenscia supports the GreenFacts’ initiative to translate the available scientific information into Dutch. GreenFacts is a non-profit project which brings complex scientific consensus reports on health and the environment from international organisations such as the WHO (World Health Organization), FAO (Food and Agriculture Organization), IARC (International Agency for Research on Cancer), UNEP (United Nations Environment Programme), and the European Commission) within the reach of non-specialists. GreenFacts publishes clear, faithful and verified summaries of existing scientific reports on health, the environment and sustainable development. These are peer reviewed under the control of an independent scientific committee.