Consumption of hazardous chemicals

The Seventh Environment Action Programme (7th EAP) includes an objective of assessing and minimising risks to the environment and health associated with the use of hazardous substances. The consumption of chemicals provides benefits to society, but can also entail risks to the environment and human health. Risk depends on both the intrinsic hazard of chemicals and exposure to them, and while data on the hazardous properties of chemical substances is improving, the data quality is often unsatisfactory, and environmental and human exposure is poorly documented. The consumption volumes of industrial (i.e. manufactured) chemicals that are hazardous to human and environmental health are used as a rough proxy for exposure. From 2004 to 2016, the consumption of these hazardous chemicals declined by almost 11 % in the EU. This may indicate the move of the production of some hazardous chemicals outside Europe and/or a shift towards safer chemicals. However, as consumption volumes are not directly related to risks to the environment and to health from exposure to chemicals, the decline provides a weak indication of progress towards the objective. Furthermore, the indicator does not include some types of hazard, exposure from chemicals in imported products and from accumulated chemicals, and it does not take changing exposure patterns or mixture toxicity into account. Therefore, this briefing rather serves to highlight gaps in the evidence base for assessing risks to the environment and to human health associated with the use of hazardous substances.

Setting the scene

The 7th EAP (EU, 2013) includes a number of chemical-related goals, one of which is 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 (CLP) 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 along the chemical life cycle (i.e. production, use, and disposal/incineration/recycling) can generate significant risks to health and ecosystems. The risk of disease is a combination of how hazardous (toxic) the chemicals are and how great the exposure is. Exposure is a result of the combined exposures to single chemicals from various sources, but also from mixtures of chemicals with various toxicities (Bopp, 2018). Hazardous chemicals have been detected in human populations and linked to environmental, product and dietary exposures (Smolders et al., 2015), as well as to workplace exposures. Human exposure to chemicals may lead to different disease outcomes such as allergy and cancer (Prüss-Ustün et al., 2011). Chemical pollution can degrade air and water quality, and can impact negatively on ecosystem services (Gross and Birnbaum, 2017), and terrestrial life (Hallmann, 2017) as well as aquatic organisms (Malaj, 2014).

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 has 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). 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 indentified as SVHCs, it does not indicate if the replacement chemicals are of similar or less concern. The 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’. Nevertheless, progress is slow because of low quality data (ChemicalWatch, 2017).

In this context, it was found (UBA, 2015) that for chemicals that are produced in quantities greater than 1 000 tonnes/yr, only one (1) of the 1 814 investigated registration dossiers submitted to the European Chemicals Agency under REACH was compliant. A total of 58 % were ‘non-compliant’ and the remaining 42 % were inconclusive, mainly as a result of poor quality data and non-conclusive results.

Figure 1 provides an EU overview of the total consumption of chemicals and the proportion that is hazardous to health and to the environment. It covers the 2004 to 2016 period.

Figure 1. Consumption of chemicals that are hazardous to health and the environment, EU

Note: The consumption volumes are apparent as they are calculated by adding the net imports (imports minus exports) of chemicals to the production volume of the chemicals.

The total consumption of ‘hazardous and non-hazardous' chemicals decreased by 7 % between 2004 and 2016. The most significant decrease took place between 2007 and 2009 (21 %), mainly as a result of the 2008 economic downturn including its aftermath in 2009 (CEFIC, 2014). 

Over the 2004-2016 period, the consumption of hazardous chemicals decreased by almost 11 %, both for chemicals that are hazardous to the environment and for chemicals that are hazardous to health. The tonnage proportion of chemicals that are hazardous to health in the total consumption of chemicals (hazardous and non-hazardous) decreased from 65 % in 2004 to 62 % in 2016. The proportion of chemicals that are hazardous to the environment decreased from 37% to 35% over the same period^[2]. The 11 % decrease in the total tonnage consumption of hazardous chemicals may have been partly caused by a move to produce chemicals (hazardous and non-hazardous) outside Europe (OECD, 2012), as well as by some substitution of substances of high concern (SVHCs) with safer chemicals, as also noted by Eurostat (Eurostat, 2012).  

It is assumed that reduced consumption volumes of chemicals that are hazardous to human and environmental health will equate to a reduction in the total risk posed by chemicals, including those incorporated into products and sold in the EU. This analysis draws on the fact that risks are a combination of how hazardous the chemical is and how high the exposure is. Risk is calculated as follows: Risk = Hazard x Exposure. If there is no consumption, there is no exposure and there will be no risk. Similarly, if the chemicals pose no hazards, there will be no risk.

In practice however, the picture is a bit more complicated. A chemical may pose several types of hazards (toxicities) and combined exposure to multiple chemicals can add up and cause mixture toxicity (Bopp, 2018). The information on the types, potency and mixture toxicity of the hazards is currently incomplete. For example, developmental toxicities (endocrine disruption, neurotoxicity and immunotoxicity) (3) and nanomaterials are not specifically addressed by the CLP criteria. In addition, it is primarily the most consumed chemical substances (in tonnes) in the EU that are undergoing an extensive hazard evaluation (ECHA, 2018), with the consequence that hazards from the least consumed chemicals (tonnes) are not as rigorously assessed. Furthermore, the type of hazard and its potency may change as the initial ‘chemical ingredients’ react to produce other chemical products (e.g. polymers) and by-products, which are not evaluated. This adds uncertainty to the list of ‘non-hazardous’ chemicals in the current indicator.

Similarly, there are a number of difficulties in assessing exposure. In particular, the indicator does not include a number of exposure types and routes to humans and the environment that add to exposure.  For example, the indicator does not include the chemicals used in the past which are still present in old materials including in recycled materials or which have accumulated in the environment, due to their persistency or high use volumes. For instance, old and recycled products may contain polychlorinated biphenyls (PCBs) in buildings (Wöhrnschimmel, 2016) or brominated flame retardants (BFRs) in furniture and electrical appliances (EEB 2017, EC 2018a). Furthermore, the indicator does not take into account the pollution that originates from production outside of the EU and which can be transferred via air, water and via products into the EU. It is, therefore, of concern that the global production and consumption of chemicals is increasing (OECD, 2012; Bernhardt et al., 2017: CEFIC, 2018). 

These factors make it difficult to use EU consumption volumes of chemicals that are hazardous to health and the environment as a proxy for risks presented by those 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, positive that there has been a decline of 11 % in the consumption of chemicals that are hazardous to the environment and health since 2004. The question is, however, if this positive trend is offset by other exposures not included in this indicator, namely via chemicals in imported or recycled/reused products, from accumulated persistent and legacy chemicals or from environmental contamination along the chemical’s production, use, disposal and recycling life cycle. This questions the ability to reach the objective by 2020.

Outlook beyond 2020 

The outlook beyond 2020 is uncertain for a number of reasons. 

The global production of chemicals is foreseen to increase (OECD, 2012; Bernhardt et al., 2017 and CEFIC, 2018). Increased exposure will become more common. The need to recycle resources and a circular economy may keep populations exposed to legacy chemicals in recycled products and increased flooding due to climate change may remobilise deposited chemicals (EU, 2013; EC, 2017; Bogdal, 2009). In addition, trends in urbanisation and the tendency of people to spend more time indoors will increase exposure to indoor and outdoor air pollution.  

As mentioned previously, estimating chemical risk is difficult because there is incomplete information on the hazards of chemicals to both humans and the environment. It is, however, certain that chemicals for which its hazards and exposure have not yet been characterised, do pose a risk, and that higher exposure leads to higher risk. There is also a lack of information on exposure levels, as well as on associations between exposure and impact to humans and to the environment, and the causal mechanisms involved. For humans, recent EU funded research aims to close that gap by using human biomonitoring to generate evidence for the link between exposure to mixtures of chemicals and the health of the European population (EEA, 2018).

The importance of achieving a high level of protection of human health and the environment through a non-toxic environment strategy — as foreseen in the 7th EAP by 2018, — was emphasised by the European Environment Council in their conclusions from 19 December 2016 (Council, 2016). The non-toxic environment strategy should address the sensitivity of vulnerable groups, very persistent chemicals, endocrine disrupting chemicals and exposure to chemicals in products. Recent initiatives by the EU, Member States and the OECD aim to increase the use of less hazardous chemicals by promoting the innovation and use of non-chemical alternatives, and chemicals and products that are safer-by-design across their entire life cycles (EEA, 2018). The recent REFIT exercise that assessed the effectiveness and coherence of the EU chemicals legislation (EC, 2018b and 2018c) found that there is a need to speed up the substitution of hazardous chemicals with less hazardous alternatives. It identified the benefits of developing cross-horizontal legislation criteria for the identification of hazards such as persistency and endocrine disruptors (EDs), of grouping chemicals more widely, and of addressing combined exposure and mixture toxicity. It also found that certain areas such as workplaces need more attention to reduce exposures to e.g. carcinogens, mutagens and reproductive toxicants (CMRs). Moreover, it found that the issue of tracking chemicals of concern in products — particularly imported, reused and recycled products — needed more attention to guarantee the quality of these products.

In 2002, participants at the United Nations World Summit on 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 the Rio+20 conference (UN, 2012). Furthermore, work has been launched by the UN 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 the availability and sustainable management of water and sanitation for all.  

About the indicator

The indicator tracks the consumption of industrial (i.e. manufactured) chemicals that are hazardous to human health and the environment. The consumption indicators build on the results of the production indicators. The consumption volume is apparent and is calculated by adding the net imports (imports minus exports) of hazardous chemicals to the production volume of hazardous chemicals (Eurostat, 2017). 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 have an 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). Further information on how the toxicity classes are assigned is available in EC, 2016.

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 a rough 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 also described in the policy targets and progress section.