Bättre EU-regler för en giftfri miljö - Kemikalieinspektionen

Exposure to cadmium has again been identified as a public health problem, both in Sweden
and in accordance with assessments made by the EU’s Food Safety Authority. Measures for
reducing exposure to cadmium are now being discussed in Sweden. Cadmium is, however,
also a European problem and there is reason to consider whether Sweden should push for the
EU to devise a new cadmium strategy.
Children and chemical safety (Chapter 9)
Children and young people can be more vulnerable than adults to chemical exposure. There is
no uniform methodology in the EU which describes how the risks to children are to be
assessed, other than that used for adults. There are, however, many rules in specialist areas
which are aimed at protecting children, e.g. in the area of foods. The lack of an enhanced
methodology regarding the effects on children is, however, a problem when regulations
require industry to assess risks under its own responsibility as is the case, for example, in
REACH. Improved rules and guidelines are needed in REACH with regard to the impact of
chemicals on children, which can include test methods, test strategies and risk assessment
methodology.
We consider that requirements on chemicals are needed at the EU level with regard to
categories of articles with which children come into contact and where exposure to hazardous
chemicals can occur. We have identified textiles as one such area and propose that special
rules be introduced in this sector.
We consider that Sweden should work at EU level to ensure that a broad group of substances
harmful to health should be banned in products with which children can come into contact.
This relates in particular to substances of very high concern, which should include endocrinedisrupting
substances, but also for example allergenic substances. The existing limit values
for lead in toys must be lowered substantially in view of new scientific findings.
REACH and CLP (Chapter 5.1)
REACH is a new and comprehensive EU regulation which governs chemicals for general use.
It deals with industry’s responsibility for producing fundamental knowledge through
registrations and risk-assessing chemicals, but also the authorities’ in-depth evaluation of
prioritised substances. There are rules regarding information for users and of risk
management through authorisation and restriction decisions. The other major regulation, CLP,
contains the criteria for the classification of hazardous chemicals and labelling requirements.
REACH has a general orientation which accords well with Swedish priorities, e.g. with regard
to the responsibility of industry, the aim of phasing out substances of very high concern and
the application of the substitution principle. The legislation is new and a fundamental
objective must be to ensure that it is applied effectively. It is essential that the registration
dossiers provided by industry are of high quality for the functioning of the system. We
propose that the European Chemicals Agency (ECHA) be tasked with producing a special
report on how the fundamental requirements are met in registrations, e.g. with regard to
information requirements (test data), risk assessment of the various areas of use of substances
and the assessment of environmental and health risks in connection with waste management.
There are gaps and shortcomings in REACH, and we point out what the most important needs
for development are in our view:
• Information requirements for chemicals which are handled in small volumes are
completely inadequate. We propose that Sweden should pursue the matter of improving
the requirements prior to the registration of approx. 20 000 substances which will take
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