IFEATWORLD July 2022

16
WORLD
THE NEW EU CHEMICAL STRATEGY FOR SUSTAINABILITY CSS
COVERS REGULATORY AND NON REGULATORY MEASURES
THE EU GREEN DEAL AND CHEMICALS STRATEGY FOR SUSTAINABILITY (CSS)
Key regulatory actions Key non-regulatory actions
STRENGTHENING EU’S STRATEGIC AUTONOMY
• Identification of strategic dependencies and value chains
• Engage with stakeholders to increase the EU’s strategic foresight on chemicals
SUPPORTING INNOVATION TOWARDS SUSTAINABLE CHEMICALS
• Develop safe and sustainable by design criteria
• Funding advanced materials, smart technologies and new business models
PROMOTE UNITED NATIONS GLOBALLY HARMONIZED SYSTEM (GHS) GLOBALLY
2020 2021 2022 2023 2024
products. IFRA advocates that the
introduction of new hazard classes
should first take place under the
UN Globally Harmonized System
of Classification and Labelling of
Chemicals to ensure a level playing
field.
A further issue relates to the
compliance, enforcement, and
enforceability of the proposed new
CSS framework legislation. IFRA and
its industry partners advocate that
no restrictions or bans should be
adopted if enforceability cannot be
demonstrated by the EU, ensuring that
responsible actors are not negatively
impacted by such new rules. A
Commission-sponsored high-level
roundtable, including industry CEOs,
has been looking at this point and has
jointly with the Commission developed
recommendations.
Since the launch of the CSS proposals,
IFRA has been actively engaged
in the political process, working
directly with politicians, regulators,
industry partner associations, think
tanks and other stakeholders. We
have expressed our concerns about
COMMISSION ESTABLISHED A HIGH-LEVEL ROUNDTABLE WITH STAKEHOLDERS,
INCL. INDUSTRY REPRESENTATIVES TO REALISE THE STRATEGY’S OBJECTIVES
SETTING ESSENTIAL USE CRITERIA
TARGETED RE-OPENING OF REACH
CLASSIFICATION, LABELLING AND PACKAGING (CLP)
New hazard categories endocrine disruptors
& persistent chemicals
IMPLEMENT ONE SUBSTANCE ONE ASSESSMENT
certain elements of the CSS to the
Commission, responded to all relevant
EU consultations and started political
outreach in Brussels and, with the
support of IFRA’s network of National
Associations, in EU member states.
In France, for example, growers of
lavender and other raw materials in
the south of France have mounted
a strong advocacy campaign with a
focus on specific local issues resulting
from the proposals, complementing
IFRA’s high-level messaging.
Data underpins our approach. IFRA
has commissioned a socio-economic
impact assessment of the CSS on the
fragrance industry. The study is based
on the common EU Better Regulation
Methodology, a methodology also
followed in similar CSS impact
assessment studies by partner
associations. Thirty companies, large
and small, have contributed data to
the report, looking at the impact on
the range of fragrance ingredients in
use today and determining how the
tougher new CSS rules – including
greater scrutiny of low-tonnage
ingredients, grouping of materials for
assessment, and essential use criteria
– would affect their use in consumer
products.
This in-depth report will be published
before the summer and will be one
of the key pieces of evidence for the
fragrance industry as we seek to
shape the CSS and ensure it is both an
ambitious and workable policy.
In conclusion, the EU stated its
intention to depart from existing
processes and introduced a paradigm
shift in European legislation through
the CSS. The EU also signalled its
desire to accelerate and simplify the
legislative process through novel
concepts like essentiality, or through
the Generic Risk Approach, the One
Substance, One Assessment Approach,
as well as through non-regulatory
actions to support innovation towards
sustainable chemicals and develop
safe and sustainable by design criteria
for such approaches.
2022 is therefore a pivotal year. By
strengthening voices from throughout
the fragrance value chain and beyond,
we can build a coalition to ensure a
reasonable, proportionate, and science-