Regulators, civil society and industry spoke about the need to create a more level-playing field for alternative providers to hazardous chemicals. Key stakeholders sat together on 16 May during an EU Green Week event, co-organised by Fipra, the European Environmental Bureau and the Permanent Representation of the Netherlands to the EU. They identified a number of ways to spur the substitution of hazardous chemicals under REACH.

Suggestions for a way forward include:

  • The gladiator position of alternative providers: Alternative providers are challenging the status quo in an industry, made up by the incumbent SVHC but also their users/customers, lateral suppliers of additives and services, etc.: a whole ecosystem. They might also be bound by NDA’s and other legal obligations. So, alternative providers face a lot of resistance which does not make it easy for them to advocate for their solutions.
  • What can be done better: Alternative providers would benefit from a level playing field: if there is fair competition there will be an incentive for substitution. Concretely this could mean that they would be allowed to manifest themselves earlier in the authorization process, and ideally even before application but should, themselves, also get better organized to make their case and participate. There is also a need for more legal certainty, more enforcement, more EU internal market (can hazardous chemicals still come in from abroad?), more EU funding for substitution but also for facilitating a just transition for existing operations.
  • Risk and speed to market: The real risk is that innovative EU substances cannot make it to market, that they cannot cross the valley of death because the regulatory process is too slow and rigid / closed off for them. They then go bankrupt or move to other places in the world, leaving Europe with less innovation and competitiveness – which are two of the four primary objectives of REACH.
  • We can only do it together: In order for sustainable progress or – progressive substation – we need to have an inclusive process where everybody plays his/her role and engages in a forward looking way: We therefore call on the European Commission to make 2020 the European year of sustainable innovation, promoting safer chemicals, a cleaner environment and more competitiveness and innovation – we hope it is an invitation to take the next step in REACH. Together.