Europe has issued a new Chemicals Strategy for Sustainability with potentially far-reaching implications. How feasible are the European Commission's plans, though, and most importantly, what are the practical effects? Various of Royal HaskoningDHV's experts reflect on the Chemicals Strategy's (possible) implications in this series of blog posts. In our third post, Berend Mensink discusses the concept of Safe by design.

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Society's desire to reuse products and minimise their harm leads to an ever-growing number of new safety requirements. Requirements for the entire production chain, including the design phase: safe by design. There are two ways of ensuring a product's safety. The first way is to avoid using harmful substances. This requires knowing exactly which substances are used both in the product and during production. The second way is to ensure that substances in the product do not cause harm to people and the environment. Whether this happens depends strongly on how the product is used. Using the product does not necessarily equate exposure to harmful substances. Take a bullet for example: potentially fatal when in a gun, harmless when held in your hand. 

The focus on reusing and recycling in the European Union's Chemicals Strategy has led to a shift in safety needs and requirements. We accept fewer risks than we used to. Returning to the bullet example: it isn't enough to simply make sure the bullet doesn't end up in the gun. The reason for this is the following: in the past, companies used to focus mainly on price. Sometimes, the potential risks of harmful substances were accepted as these substances didn't cause damage when a product was used as intended. Or because people and the environment weren't exposed to a product's harmful substances when using the product as permitted. These arguments are much less relevant when it comes to reusing or recycling products. In those cases, there is a greater risk of exposure which makes it much harder – if not impossible – to recycle materials. As such, the pursuit of circularity further justifies the need to reduce the use of harmful substances in (the design of) the product.

Reducing the use of harmful substances looks easy enough: simply implement a legal ban on the use of a harmful substance. But as Leo van der Biessen wrote: this is only the first step; monitoring compliance is essential. And monitoring isn't the only thing to bear in mind: you will need to have safe alternatives in place as well. This is where it becomes tricky, because there's often a lack of ready-to-use, non-harmful alternatives. As such, there may be negative social consequences to eliminating harmful substances, besides the obvious positive ones. If a harmful substance is essential to a product and there is no technical or economic alternative, a ban on the substance may also mean a ban on the product – a potentially much more undesirable effect. A good example of this are octylphenol ethoxylates, a group of harmful substances that are crucial to the production of vaccines and medical diagnostics. This example clearly shows the dilemma surrounding this topic. 

It is essential that alternative substances are available, or a ban might not be the preferred solution. This requires research and innovation. But who will be paying for this? For most individual companies, the cost is too high. Innovation shared by several companies in a chain may spread the investment risks but poses the issue of intellectual property. It also tends to take extensive research and use of the product to determine whether an alternative substance may be carcinogenic or allergenic. Take nanotechnology, for example. This is an area we still know relatively little about and the assessment criteria for safe design and safe use are still in development. Governments must do more than the prohibition of harmful substances alone. They must contribute to finding non-harmful alternatives by facilitating innovation, funding both fundamental and applied research and bringing innovative parties together.

Does this mean that companies should just wait until a harmful substance has been banned and a safe alternative has been found? Certainly not! The demand for circular products will not lessen any time soon, and neither will society's demand for safe, healthy and eco-friendly products. The general public also has an increasingly positive view of innovative companies with a green image. This means that there's a great risk – a much larger risk, perhaps – in doing nothing. Companies that fail to innovate are less attractive to investors, and it's those investors that are desperately needed for the innovation of substances or production methods. A company that doesn't act and fails to respond to the demand for cleaner and safer products will eventually miss out. It will be left with harmful products that cannot be recycled and that no one wants.


In October 2020, the European Commission presented its Chemicals Strategy for Sustainability. This strategy focuses on protecting citizens and the environment and encouraging innovation towards safe, sustainable chemicals. The Commission links its strategy to the EU's equally ambitious Green Deal, an important re-assessment of our society's future approach to raw materials and substances. Striving for zero pollution, zero waste and zero tolerance is the goal. Royal HaskoningDHV's experts reflect on what that means in a series of blog posts. Steven Lemain and Leo van der Biessen wrote earlier blogs.