Anything EU can do we can do better? How the UK Chemical Strategy can help the environment

With the EU Chemicals Strategy hot off the press we look ahead to the UK chemical strategy to how it could go even further in tackling pollution. 

With modern society dependent on industrial chemicals and chemical production set to double by 2030 it is essential that chemicals are made sustainably, used wisely and the risks to the environmental and health are minimised.  Fidra welcomes the commitments in the EU Chemicals Strategy which aims to tackle toxic chemical pollution and support sustainable chemical use. The UK’s long-awaited chemical strategy is currently in development. There is little information about what is likely to be in the UK Chemical Strategy or how the public and civil society can input. But any nation would want a chemical strategy that delivers for as many people as possible, this can be achieved by tackling hazardous chemicals whilst ensuring the chemicals we need for a cleaner, greener society are available. Many of Fidra’s Chemical Pollution Prevention Principles feature in the EU Chemicals Strategy and there are steps the UK can take to put these principles into practice.

Chemical information is key

Europe are advocating a shift to chemicals that are safe and sustainable by design. This seems like a good step forward. At the moment there are too many hazardous chemicals on the UK and EU market and chemical pollution is harming people and the planet. Some toxic substances have been identified but are poorly regulated, others have reached the market and are causing harm because they were not properly assessed for the damage they could do before being used.  For example chemicals toxic to reproduction are being used on receipts and food packaging. Chemicals with this potential to cause harm should be replaced swiftly where ever possible, and more information is need so chemicals are known to be safe before being entering the market. The EU chemicals strategy recognises more information is needed on the impacts of chemicals, including how they act in combination. It stresses that we are ‘lacking a comprehensive information base on all substances placed on the market and on their overall environmental footprint, including their impact on climate’. This means it is hard to work out which chemicals are harmful and which are sustainable. The UK chemicals strategy could improve on this with clear criteria for sustainable chemicals.

Sustainable chemicals for a circular economy

One important aspect of sustainability is how a chemical performs and interacts with people and environment throughout its production, use, reuse and disposal. It is essential we now design chemicals for a circular economy where use, reuse and recycling of safe materials is prolonged for as long as possible. Chemicals in modern materials need to be safe at every stage and in every product they could end up in. But  companies often don’t disclose what chemicals appear in products. The whole chain from manufacturers to consumers to waste operators need information to make informed choices about use and recycling. Without information on which chemicals are in products, and while harmful chemicals are on the market, we can inadvertently contaminate recycled products for years to come. In the UK we have already seen toxic flame retardants used in the electronics being found in plastic food packaging. The EU intend to ensure there is ‘’information on chemical content and safe use, through a Sustainable Product Policy Initiative and tracking the presence of substances of concern through the life cycle of materials and products’’. This tracking is critical where harmful chemicals have essential uses and cannot be substituted yet. But as well as needing to know what is in our products so we can use and reuse them safely, we also need to remove harmful substances wherever possible.

Removing the most hazardous chemicals wherever they can cause harm

The EU intend to develop ‘methodologies for chemical risk assessment that take into account the whole life cycle of substances, materials and products.’ Whilst Fidra agree we need more information on chemicals in products,  their impacts and risks, one of the simplest ways to reduce risk and simplify risk assessments is to minimise the use of harmful chemicals in products in the first place. Here the UK can take a lead and not only track chemicals through their whole life cycle but take decisive action to ban some of the most problematic chemicals to prevent them contaminating recycled products, people and the environment. For example we are advocating that swift action is taken to ban forever chemicals, PFAS in food packaging by 2022, alongside preventing the wider use of PFAS in other applications unless it is essential to society. We were pleased the EU are highlighting that ‘per- and polyfluoroalkyl substances (PFAS) require special attention, due to  the large number of cases of contamination of soil and water – including drinking water-, the number of people affected with a full spectrum of illnesses and the related societal and economic costs . The UK can go further by taking action on food packaging now.

A precautionary approach prevents pollution

The EU chemical strategy is taking a proactive and precautionary approach to regulating endocrine disruptors, persistent, mobile and toxic substances. We are looking forward to seeing how commitments such as ’endocrine disruptors are banned in consumer products as soon as they are identified’ are put into action. This is another area where the UK can take decisive action by banning all bisphenols in till receipts. Currently the EU has only banned bisphenol a (BPA), a known endocrine disrupter which is toxic to reproduction, but other bisphenols like BPS, that are very similar in terms of risk and hazard, are taking the place of BPA.

Group chemicals in restrictions to speed up & simplify legislation

The current EU chemicals management system REACH is world leading but the EU chemical strategy recognises ‘’policy must evolve and respond more rapidly and effectively to the challenges posed by hazardous chemicals’’.  Current legislation has been slow to identify and restrict hazardous substances and often allows one harmful chemical to be replaced by a near identical twin.  We are pleased to see the EU committing to streamlined processes, grouping chemicals to prevent regrettable substitution and to taking a generic approach to risk assessing chemicals that are carcinogenic, reprotoxic and endocrine disrupters. These measures could prevent a hazardous substance ever reaching the market if similar ones are already a concern. Currently legislators are always running to catch the next hazardous chemical after it has been released onto the market and caused harm. Grouping chemicals in legislation ensures preventative measures are in place. This group based approach to managing chemicals is something successive Defra Ministers in the UK have advocated.  We have used group based legislation to tackle everything from ‘legal highs’ to CFCs that destroy the ozone layer. Now this group based approach needs to be the standard model for managing chemicals, making legislation faster, simpler and more effective in preventing pollution than the current system of assessing and restricting chemicals one by one.

Consumer products

It may seem obvious but the EU is highlighting the need to minimise the presence of substances of concern in products.  The EU Chemical Strategy wants to ensure ‘food contact materials, toys, childcare articles, cosmetics, detergents, furniture and textiles – do not contain chemicals that cause cancers, gene mutations, affect the reproductive or the endocrine system, or are persistent and bioaccumulative.’ Many people would assume this is already the case but the current regulations need strengthening and harmonsising so that when a substances is identified as toxic to reproduction, like bisphenol A,  and has been found to transfer to people through contact with the skin and through contact with food, then is is banned from food packaging, lunch boxes and till receipts. At the moment this is not that case, with different regulations on different uses and sectors for the same chemical.  So just because a chemical is banned in one product it doesn’t mean it is banned in other products that may also cause exposure. We agree with the EU that endocrine-disrupting chemicals, like bisphenols, require specific attention because they impact hormones which control development and growth: ‘exposure to endocrine-disruptors during foetal development and puberty can lead to irreversible effects, some being detected only many years later.’ We hope to the UK chemical strategy outlines policy changes and legislation that protect consumers and the environment from chemicals of concern.


Many nations have struggled to enforce chemical legislation and meet environmental targets. In the UK we need more regular and rigorous monitoring of products, industrial site, waste centres and wastewater treatment plants as well our environment. This must be supported and resourced alongside stronger enforcement action in line with the polluter pays principle. Our environmental laws need to be overseen and upheld by an independent watchdog with the power to hold government to account.

Essential use

Another concept that is given prominence in the EU chemical strategy is only using harmful chemicals where they are essential for society. As a pragmatic evidence based organisation Fidra recognises that in certain circumstances there may be no current alternatives but to use a hazardous chemical (for example toxic metals are sometimes needed to make medical equipment) but this provision for using a hazardous substance most only be applied where the use is essential for society and there is no alternative. By only allowing hazardous chemicals to be used in a limited number of essential uses, where there is currently no alternative, we can reduce the potential for harm. Just because we need a hazardous chemical for a specific function doesn’t mean we should accept its use in all circumstances and the search for alternatives (even for these essential uses), must be on going and incentivised with support for research and innovation in green chemistry.

Will the UK chemicals strategy be worth the wait?

It is good to see the EU chemical strategy taking a proactive and precautionary approach to regulating chemicals to support their vision of a toxic free future. We look forward to seeing how Europe will put into practice sharing chemicals information, shifting to sustainable chemicals and essential use principles. If the UK no longer subscribes to the EU chemical policies as the Transition Period ends it becomes more important than ever that the UK takes a world leading role in tackling chemical pollution. We need a UK Chemical Strategy that sets out how we are going to stop pollution now and prevent it in the future. The UK can have a tangible impact  by outlining specific commitments, timelines and support available to implement and enforce them. If we are to remove the burden chemical pollution places on our health and environment the UK needs an ambitious strategy with the resources, legislation and environmental bodies needed to make chemicals sustainable, products safe and our environment healthy.


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