Would the introduction of the essential use concept help to improve the enforcement of chemical legislation in the EU, asks Marko Sušnik of SMEunited
Enforcing the essentiality of chemicals
Would the introduction of the essential use concept help to improve the enforcement of chemical legislation in the EU, asks Marko Sušnik of SMEunited
For chemicals, the EU‘ s Chemicals Strategy is one of the most important building blocks of the EU’ s Green Deal. 1 This strategy includes a long list of actions that were implemented after its publication in 2020.
One of these was the development of criteria for what essential and non-essential uses of a substance are( Figure 1). This element became known, as the essential use concept( EUC). It was published as a communication of the European Commission in 2024, shortly before the EU elections. 2
The scope of the EUC is relatively wide and includes the so-called most hazardous chemicals( MHCs). This group of chemicals is linked to a significant number of CLP hazard properties:
• Carcinogenicity, Cat. 1A & 1B
• Germ cell mutagenicity, Cat. 1A & 1B
• Reproductive / developmental toxicity, Cat. 1A & 1B
• Endocrine disruption, Cat. 1( human health)
• Endocrine disruption, Cat. 1( environment)
• Respiratory sensitisation, Cat. 1
• Specific target organ toxicity – repeated exposure( STOT-RE) Cat. 1, including immunotoxicity & neurotoxicity
• Persistent, bioaccumulative & toxic / very persistent & very bioaccumulative( PBT / vPvB)
• Persistent, mobile & toxic / very persistent & very mobile( PMT / vPvM)
• Hazardous to the ozone layer, Cat. 1
It is too early to say how many substances that would be exactly, let alone how many uses of substances. Nevertheless, a search in ECHA’ s Classification
Figure 1 – Guiding criteria & principles for essential use
& Labelling Inventory( CLI) today gives a result of more than 11,500 hits when filtering the inventory for MHC properties. 3
This number certainly will not decrease, considering that the EU’ s CLP regulation was recently extended for properties related to endocrine disruption and persistency. Consequently, not many
54 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981