Course Description:
The substitution principle is an important cornerstone of many chemical regulations in the European Union, such as REACH and the Biocidal Products Regulation (BPR). It aims to encourage the replacement of substances of concern with suitable alternative substances or technologies as and when they are economically and technically viable. In practice, drawing conclusions on the viability of alternatives to substances of concern is complex. A particular challenge for substitution lies with small and medium-sized enterprises (SMEs) who typically do not possess the resources to adequately identify and assess all potential alternatives. All efforts to avoid regrettable substitutions must remain essential.

This session will discuss the existing use of the substitution principle in the EU regulatory framework and how attitudes towards substitution differ between stakeholders, such as those in industry or non-governmental organizations. The session will address how the substitution principle might play a part in proposed adaptations to REACH arising from the Chemical Strategy for Sustainability, including reform of authorization and the introduction of the concept of essential use. The session will also introduce concepts being actively researched in the EU that might mean substitution will not be needed in the future.

Contact Hours:
0.5 Contact Hours

Presentation Date:
10/20/2022

Presenters:
Max Moseley