Consumption of hazardous chemicals

Setting the scene

The 7th EAP (EU, 2013) includes a number of chemical-related goals, one of which states that health and environmental risks associated with the use of hazardous substances, including chemicals in products, should be assessed and minimised by 2020. Under the Regulation on the classification, labelling and packaging of substances and mixtures, chemicals are classified as hazardous on the basis of properties that generate physical, environmental and health hazards (EU, 2008). While the consumption of chemicals provides benefits to society, exposure to hazardous chemicals emitted throughout the chemical life cycle (i.e. production, use and disposal/incineration/recycling) can generate significant risks to health and ecosystems. Impacts of chemical exposure to humans and the environment is a result of the sum of exposures from a multitude of sources, from mixtures of chemicals with various toxicities. Such health impacts are associated with a number of disease outcomes (Prüss-Ustün et al., 2011), while chemical pollution degrades air and water quality, and can impact negatively on ecosystem services. Hazardous chemicals have been detected in human populations and linked to environmental, product and dietary exposures (Smolders et al., 2015), as well as workplace exposures.

Policy targets and progress

The Regulation on the registration, evaluation, authorisation and restriction of chemicals (REACH) (EU, 2006) aims to improve the protection of human health and the environment from the risks posed by chemicals. REACH also calls for the progressive substitution of the most hazardous chemicals, when suitable alternatives have been identified ^[1].

Eurostat developed a set of indicators to monitor progress towards two major goals of REACH: to improve the quality of data for chemical risk assessment, and to reduce the risks posed by chemicals to humans and the environment (Eurostat, 2009). An analysis using these indicators suggests that REACH implementation resulted in better risk control of known chemicals of concern, for which specific actions had been set, e.g. for substances of very high concern (SVHCs) (Eurostat, 2012). However, since the SVHC indicator only measures chemicals registered as SVHCs, it does not indicate if the replacement chemicals are less toxic. Regulation of groups of chemicals rather than single substances is being considered by the European Commission (EC, 2017) as a means to speed up the risk assessment and to avoid the so-called ‘regrettable substitution’.

Figure 1 provides an EU overview of the total consumption of chemicals, and the proportion that is hazardous to health and the environment. It covers the 2006-2015 period.

Figure 1. Consumption of chemicals, by hazard class, EU

There has been a 7.5 % decrease in the consumption of ‘hazardous and non-hazardous' chemicals; the non-hazardous chemicals included here are chemicals that might have hazardous properties, but which are not classified as such. The main decrease took place in 2009 (it dropped by 19 % compared with 2006), following the aftermath of the 2008 economic downturn. From 2009 to 2010, consumption increased by 16 % and has remained more or less stable since then. Similar trends are seen for chemicals that are hazardous to human health (-8 % in the 2006-2015 period) and for chemicals that are hazardous to the environment (-10 % in the 2006-2015 period). 

Looking at developments from 2013 to 2015, there was a small increase of 3.1 % in the EU’s total consumption of hazardous and non-hazardous chemicals, as well as in the consumption of chemicals that are hazardous to health and to the environment. 

For chemicals that are hazardous to the environment, the ‘moderate chronic environmental hazard’ decreased by 8.8 %, but this has been offset by increases in the four other hazards, including the two most hazardous (‘severe chronic’ and ‘significant chronic’).

Likewise, in the same 2013-2015 period, ‘chronic toxic health hazards’ decreased by 8.5 %, but all the four other health hazards increased, including substances that are carcinogenic, mutagenic and toxic for reproduction (CMR substances). These are considered to pose the most significant risks to human health. However, from 2006 to 2015, the EU chemical consumption of CMR substances declined by 12 %. This trend may be indicative — considering the indicator limitations outlined below — of a decrease in consumption of chemicals of high concern, driven by substitution, as was also seen in the Eurostat report ‘The REACH baseline study 5 years update’ (Eurostat, 2012).  

In making the link between the consumption of chemicals that are hazardous to human and environmental health and the resulting risks, the assumption is that reduced consumption volumes will equate to a reduction in the overall risk profile of chemicals, including those incorporated into products and sold in the EU.

However, consumption volumes for chemicals that are hazardous to health do not provide direct insight into risks, since consumption is not synonymous with exposure, nor does it consider the specific toxicity of the chemicals. On the one hand, some chemicals are handled in closed systems, or as intermediate goods in controlled supply chains, implying that no, or limited, exposure takes place (Eurostat, 2014). On the other hand, a number of factors have not been included in the consumption of chemicals, which may contribute to exposure. For instance, it is possible that reductions in the consumption of chemicals that are hazardous to health are being offset by increased imports of products that contain such chemicals, potentially leading to exposure throughout the product life cycle, inside or outside the EU. Accumulated persistent and legacy chemicals will add to human and environmental effective exposure. Production of chemicals in the EU, which are not consumed, but exported, can pollute at the location where the production occurs. Likewise, chemicals that are produced and used outside Europe can reach Europe via air, water and food as well as in products. It is, therefore, of concern that the global production and consumption of industrial chemicals is increasing (EU, 2017 and Bernhardt et al., 2017). 

Another limitation of using this indicator to describe risk, is that the information on the types and potency of the hazards is incomplete. Endocrine disruptors, mixture effects and nanomaterials are not specifically addressed. Early exposure to chemicals having neuro-developmental toxicity and immuno-developmental toxicity may lead to late and inter-generational effects and this is not consistently addressed in the hazard evaluations. In addition, many substances on the market may have unrecognised hazardous properties and may consequently not be listed as hazardous, and not included in the current indicator on substances with known hazardous properties.

These factors make it difficult to use EU consumption volumes of chemicals that are hazardous to health and the environment as a proxy for risk to chemicals. It is, therefore, not possible to accurately report progress towards the goal of minimising risks to the environment and health on the basis of this indicator. It is, however, of concern that the consumption volumes have more or less stabilised since 2011. This may question the ability to reach the objective by 2020.

Additional concerns focus on the health impacts of chemicals that are endocrine disruptors, toxic to the neuro- and immunodevelopment of unborn children, persistent chemicals accumulating in humans and the environment, nanomaterials and effects of combinations of chemicals. The indicator on the consumption of chemicals that are hazardous to health and the environment does not provide specific insight on these concerns.

Outlook beyond 2020 

Chemical risk is an area characterised by incomplete information on the hazards posed by chemicals, uncertainties regarding exposure levels, as well as the associations between exposure and health outcomes, and the causal mechanisms involved. New initiatives to generate data on the link between exposure to chemicals and the health of the European population using human biomonitoring should serve to improve the evidence base for strengthening the protection of human health from chemical risks. 

The outlook beyond 2020 gives cause for concern. The global production of chemicals is expected to rise (Bernhardt et al., 2017); a circular economy may increase exposure to legacy chemicals; the European population spends more time indoors and climate change may remobilise chemicals from landfill (EU, 2013 and EC, 2017).

The 7th EAP calls for the development of an EU strategy for a non-toxic environment by 2018. This should address the concerns listed above, as well as exposure to chemicals in products, including imported products. It mentions the need to promote non-toxic material cycles, to reduce indoor exposure to harmful substances, and to identify measures to decrease impacts from e.g. endocrine disrupters, persistent chemicals and nanomaterials, particularly for vulnerable groups or ecosystems. This strategy is expected to set a framework for actions to minimise chemical risks beyond 2020.

Current efforts to promote a circular economy also have implications for chemicals in products. The reuse or recycling of products that are contaminated with hazardous chemicals may lead to unforeseen exposure. Further research is required to identify material flows that may be contaminated and to understand the potential exposure resulting from recycling these materials. Such knowledge might inform decisions on how to guarantee the quality of recycled materials, for instance by separating out contaminated materials, or by using green and sustainable chemistry and non-chemical solutions. Preventing hazardous chemicals from entering material flows from the start might achieve multiple goals of increasing the quantity of recycling, while minimising risk.

The importance of maintaining a high level of protection of human health and the environment, through a non-toxic environment strategy, was emphasised by the European Environment Council in their conclusions from 19 December 2016 (Council, 2016). In August 2017, the European Commission published a final report describing the topics and listing a set of possible actions that could be elements of a non-toxic environment strategy (EC, 2017).

At the United Nations level, in 2002, participants at the World Summit of Sustainable Development, including the EU and its Member States, made a commitment to the sound management of chemicals throughout their life cycle. This commitment aims ‘to achieve, by 2020, that chemicals are used and produced in ways that lead to the minimization of significant adverse effects on human health and the environment’ (UN, 2002). This goal was reaffirmed at Rio+20 (UN, 2012), with the 7th EAP explicitly calling for action to attain this goal at EU level. Work has also been launched at the UN level to prepare recommendations for a future platform for the sound management of chemicals and waste beyond 2020. In addition, the Sustainable Development Goals (UN, 2015) set a global agenda until 2030 and define the risks from chemicals under several topics, including goals to ensure sustainable consumption and production patterns, to ensure healthy lives and promote well-being for all at all ages, and to ensure availability and sustainable management of water and sanitation for all.

About the indicator

The indicator tracks the consumption of industrial chemicals that are hazardous to human health and the environment. It includes five toxicity classes of chemicals that are hazardous to human health and five toxicity classes of chemicals that are hazardous to the environment; the classes are illustrated in Figure 1. These classes of chemicals exhibit properties that impact on human health and the environment, and are derived from the hazard statements described under the Regulation on the classification, labelling and packaging of substances and mixtures (EU, 2008).

The scope of the indicator is limited, since it does not cover all possible impacts on human health or the environment, or the ways in which exposure may occur. By taking the consumption of chemicals that are hazardous to health and the environment as an imperfect proxy for exposure, a fall in consumption may imply a reduction in exposure. However, there are a number of limitations when extrapolating exposure from consumption, as described in the policy targets and progress section.