The European Economic and Social Committee (EESC) supports the Commission's objective of moving towards a toxic-free environment and ensuring that chemicals are produced in a way that maximises their positive contribution to society and reduces the environmental impact.
A definition of what uses of chemicals are "essential" is needed, and a clearly outlined methodology for how to make chemicals "safe and sustainable by design". In this context, we emphasise that "substances of concern" must be identified, evaluated and classified in the most comprehensive, unambiguous and simplified manner so that industry can adapt.
The EESC compliments the Commission on its view that the EU should be a global frontrunner in the production and use of safe and sustainable chemicals and highlights the importance of assuring a level playing field in international trade deals for companies, and measures for a just transition for all EU citizens.
In order for the strategy to be successful, people's and industry engagement is required, as well as innovative ways of thinking, coupled with transparency and involvement in the decision-making process.
The strategy aims to extend the generic approach to risk management to consumer products containing hazardous chemicals such as carcinogenic, mutagenic or endocrine disruptors. However, to make it easier for industry to adapt, the balance between generic and risk assessments needs to be ensured.
The EESC calls for proper and consistent labelling to be mandatory, with enforcement for the whole supply chain, including products containing nanomaterials.
The EESC welcomes the effort to strengthen the EU's strategic autonomy, especially in terms of chemicals used for health applications, and wishes to see the same effort in other sectors and calls for a revision of EU Industrial Policy to be considered, with a view to relocating part of the key chemicals production in the EU countries.
The EESC stresses the importance of tackling the lack of availability of chemical data so as to boost innovation, consumers' trust and conduct proper impact assessments. It is vital to have accessible and reliable databases for research results to review the industrial property rights and patents that limit access to data, and to strengthen the principle of "no data-no market".
The EESC considers that addressing chemical mixtures is a relevant step forward in the risk assessment of chemicals. However, more research and development is crucial to cover the actual gaps of knowledge and put forward the assessment and management of chemical mixtures.