Challenges for a Sustainable Chemicals and Materials Policy
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Friends of the Earth Germany (BUND), National Working Group on Environmental Chemicals and Toxicology Challenges for a Bund für Umwelt und Naturschutz Deutschland e.V. (BUND) Friends of the Earth Germany Kaiserin-Augusta-Allee 5 10553 Berlin, Germany Sustainable Chemicals www.bund.net and Materials Policy Authors: Markus Große-Ophoff, Klaus Günter Steinhäuser, Ralph H. Ahrens, Uwe Schneidewind, Henning Friege, Arnim von Gleich, Eva Scholl, Patricia Cameron, Manuel Fernández Graphic: Mahmure Alp / Noun Project The Need for Transformation Layout: dieprojektoren.de in the Global Context Dezember 2019 We are indebted to the members of the Friends of the Earth (FoE) Germany’s National Working Group on Environmental Chemicals and Toxicology and the Scientific Advisory Board of FoE Germany for their contributions. www.bund.net/chemicals-policy www.bund.net/chemicals-policy-abstract In memory of Karl Otto Henseling CONTENTS Summary . 4 1 Introduction . 5 2 Looking back on over 50 years of debate on chemicals. 6 3 Guiding principles of a sustainable chemicals and materials policy . .. 7 3.1 The precautionary principle ............................................................ 7 3.2 Sustainability ....................................................................... 8 4 Chemicals policy is a planetary issue . 9 4.1 Global exposure to chemicals .......................................................... 9 4.2 Planetary boundaries ................................................................ 10 4.3 Planetary boundary: “Novel entities” ....................................................11 4.4 International solutions .............................................................. 12 4.4.1 The commitment of the world community ......................................... 12 4.4.2 Five global agreements ......................................................... 13 4.4.3 The SAICM discussion framework ................................................ 13 4.4.4 Globally accepted test, assessment and classification procedures ...................... 13 4.4.5 United Nations activities – Sustainable Development Goals ........................... 14 4.4.6 Despite all this: not enough! .................................................... 14 5 The EU Chemicals Regulation REACH . 14 6 Persistence and other substance-related properties . 15 6.1 Persistence as a central environmental problem .......................................... 15 6.2 (Bio)accumulation .................................................................. 16 6.3 Mobility ........................................................................... 17 6.4 Indirect effects ..................................................................... 17 6.5 Hormonal effects ................................................................... 18 6.6 Nanomaterials and other novel materials ............................................... 18 6.7 Combined effects ................................................................... 19 6.8 Trace materials in waters ............................................................ 20 6.9 The outlook: sustainable chemicals .................................................... 20 7 Materials flow management . 20 7.1 Basic principles of the Committee of Inquiry ............................................ 21 7.2 Principles of ecological materials flow management ...................................... 22 7.3 A necessary trend reversal in the production of chemicals ................................. 23 7.4 Sustainable chemistry in the circular economy. 23 7.4.1 Conflicts of goals .............................................................. 23 7.4.2 Raw material extraction and processing ........................................... 24 7.4.3 A wide range of input substances and products ..................................... 25 7.4.4 The special case of plastics ...................................................... 25 7.4.5 Product design ................................................................ 26 7.5 Service models ..................................................................... 27 8 Guiding principles for chemicals and materials policy – Recommendations by Friends of the Earth Germany . 27 8.1 Recommendations for the further development of an international chemicals policy ........... 28 8.2 Recommendations for the further development of REACH ................................. 29 8.3 Recommendations for the further development of substance evaluation and chemicals management ..29 8.4 Recommendations for sustainable materials flow management ............................. 30 8.5 Recommendations for research and education policy ..................................... 30 9 References. 32 3 EXECUTIVE SUMMARY It is quickly becoming clear: We need new approaches. Mostly it is not enough to assess one chemical on its own. Contextual thinking and action are needed. The interactions among differ- Over the past few years the use of natural resources and the ent chemicals and other stress factors – such as the changing production of chemicals have increased dramatically – and a climate – acting on ecosystems and on human health must be further increase is forecast. Whereas earlier the main focus was taken into consideration. The global dimension of materials on local effects on health and the environment, in the mean- flows must be considered as well. We need a national and glob- time it has become clear that current ways of dealing with al chemicals and materials policy that faces these challenges. natural resources, chemicals and products manufactured from chemicals are threatening the biosphere as a whole. This Friends of the Earth (FoE) Germany position paper “Chal- lenges for a Sustainable Chemicals and Materials Policy – the In 2009 and 2015 scientists introduced the concept of planetary Need for Transformation in the Global Context” presents ways boundaries [1]. As part of this framework nine areas were defined for successfully introducing a sustainable chemicals policy. in which human activities are threatening the Earth system. With Examples: Persistent substances should not enter the environ- the greenhouse gases causing climate change, the acidification ment and substantially fewer toxic chemicals should be pro- of the oceans, damage to the ozone layer, atmospheric aerosol duced. Where possible, fewer chemicals should generally be loading, biogeochemical flows of phosphorus and nitrogen as used. If a chemical or product is still used, this should be done well as “novel entities” – which scientists define as chemicals as efficiently as possible – in other words, with a high level humans have introduced into the environment that were not of benefit. At the same time, making the remaining materials present previously – six of these boundaries relate to the use of flows part of a recycling loop, optimally as a closed-loop cycle, resources as well as the use of chemicals and their emissions. should be considered. The statutory regulations for chemicals, product and waste legislation must share a common basis and The analyses show that the economic activity of humans today be closely coordinated with each other. and current lifestyles are unsustainable and exceed the limits of our Earth system. The trends in global consumption of nat- A sustainable chemicals and materials policy must also encom- ural resources and energy indicate that growth is accelerating. pass all areas of life such as mobility, housing and construction, No reversal of the trend is in sight. Humanity has already left nutrition, clothing and consumption. It thus goes far beyond the safe operating space. current chemicals policy and, similarly to environmental pro- tection, requires a comprehensive transformation of economic What contribution can a sustainable chemicals policy make? activity and consumer behavior. In this regard, chemicals policy Until now quantifying the planetary boundary for “novel enti- is closely related to protecting resources and safeguarding cli- ties” has not been successful. This is also due to the fact that mate and must be conceived and implemented while consider- the variety of substances with varying effects is increasing. We ing such protection. are only gradually ascertaining what consequences this diver- sity of substances is having on, for example, sensitive ecosys- This position paper shows: Chemicals policy must be developed tems. Many of these chemicals have been stable in the environ- with a stronger focus on preventive action and sustainabili- ment for centuries. The examples of chlorofluorocarbons (CFCs) ty. At the international level this means using the Sustainable and of plastics show that substances and materials which were Development Goals (SDGs) of the United Nations as a bench- originally assumed not to be hazardous can also cause consid- mark. In assessing chemicals, persistence must be consistently erable problems. Once released into the environment they can regarded as the core hazard. A central goal is to develop and only be retrieved again – if at all – with great difficulty. use sustainable chemicals which in particular are neither per- sistent, bioaccumulating, (eco)toxic, nor highly mobile. It was already recognized in the 1970s and 1980s that taking ac- tion only when the effects of substances in the environment have In the final chapter, “Guiding principles for chemicals and been proven beyond any doubt can be too late. That is why the materials policy – Recommendations by Friends of the Earth precautionary principle was anchored