Panel 2: Grouping of chemical substances and how to avoid regrettable substitution

1. Grouping of Chemicals
and Substitution
Helsinki Chemical Forum 2019
2 3-05-19
Maggie Saykali – Cefic Specialty Chemicals

2. Page 2
Cefic: The voice of the chemical industry in
Europe
• Based in Brussels since 1972
• One of the largest industry trade
organizations in Europe and in the world
• 30 National Chemical Federations across
Europe
• Over 500 direct Company Members from
Europe,
• 40 Associate Companies from around the
world,
• 60 Partner Companies
• More than 20 Partner Associations
• Close cooperation with the other regions in
the world through ICCA.
We interact every day on
behalf of our members with
international and
EU institutions, non-
governmental
organisations, the
international media
and other stakeholders
Over 80 sector groups
are represented by Cefic in
three industry sectors:
Euro Chlor / Halogens,
Petrochemistry Europe,
Specialty Chemicals

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The Chemical Industry and innovation
The Chemical industry thrives on innovation and
develops new chemicals every day:
700 billion EUR are invested every year in R&D
• Improving performance and functionality
• Looking for better, safer and more affordable
substances
• Meeting the needs of customers
• Anticipating new regulations

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Substitution is an innovation opportunity
The challenge: Improve performance whilst ensuring
that any potential risks are assessed and managed.
Holistic assessment based on:
• Full LC Assessment
• Technical and process performance
• Safety data
• Health and environmental properties
• Fitness for use
• Availability and affordability of raw materials
This is needed to avoid regrettable substitution.

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Substitution and beyond
• The decision to substitute is for each company to
make on an individual basis, in compliance with
competition law.
• Substitution may need time to develop new
technologies and enable investment plans.
• Substitution can go beyond the product phase,
thinking about recycling and the re-use of waste.
• Substitution is not the only possible Risk
Management Option.

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Grouping of chemicals
• Can be a useful and efficient tool if based on robust
and justified scientific criteria.
• As a tool for registration of substances.
• As a first approach for regulatory assessments.

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Grouping of chemicals
For a thorough, in-depth assessment, a one-size-fits-all
approach to regulating chemicals as a class should not
be considered.
• Substances that have a similar basic structure can
have different tox/ecotox properties.
• A similar family name is not sufficient reason for
grouping.
• Widespread adoption of standard, validated
approaches will increase trust in the results.
• ECHA guidance on grouping and read-across is a
good basis on which to build.

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In conclusion
• Substitution is an innovation opportunity.
• Substitution is one of the RMOs available but there
can be others.
• Regulators can stimulate substitution.
• The grouping of chemicals for the purpose of
substitution has to be justified on the basis of
evidence.
• Results of RMOA of substitutes have to be accepted
by all stakeholders.

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The only way forward is through
dialogue and cooperation