Ahead of this week’s EU Chemicals Policy 2030 Conference themed around “building on the past, moving to the future,” it’s the perfect moment to take stock of recent developments in the EU chemicals policy and reflect on how a future chemicals framework should look.

One of the key challenges has always been reconciling the so-called Three Cs: chemicals, climate and circular economy policies. This is particularly urgent now as the EU strives to achieve global climate commitments and is already looking into climate neutrality by 2050.

The 2030 vision of the EU chemical policy should also be fully aligned with our circularity agenda. The OECD 2019 Raw Materials Outlook foresees an increase of 270 percent in global metals demand by 2060, while Europe’s share of global mining is just 2 percent across all metals, making it strongly dependent on imports. Since recycled metals have all the same properties as primary metals, and recycling requires less energy than primary production, recycling is key part of the solution. The chemicals policy framework should therefore be designed to protect the environment and human health, yet without discouraging new investments into production and recycling of materials for an innovative European economy.

We should also ask ourselves how to make chemicals policy more sound. Could, for instance, the grouping of substances be part of the solution? This kind of framework can serve multiple purposes, such as allowing regulators to consider several substances at a time, thereby ensuring consistency, efficiency and predictability, avoiding regrettable substitution sometimes caused by the traditional substance-by-substance approach.

On the other hand, industry itself may establish grouping strategies, following the guidance from ECHA, through which conclusions for one substance are drawn based on data for another substance—the so-called read-across. At the moment however, there are no globally accepted rules or standards for grouping.

As stakeholders and policymakers look ahead this week to chemicals policy for the coming years, these two topics should be part of the conversation. We welcome the fruitful discussions!