Discussions for a renewed and updated UN chemicals strategy – currently called SAICM – are underway in the Intersessional Process.
A group of NGOs, including the ones behind this micro webpage, have closely followed this process, with the intention to strengthen work with a selection of prioritized policy areas in the strategy – so called Emerging Policy Issues and Other Issues of Concern. Among them is the Emerging Policy Issue Chemicals in Products (CiP). So far, the CiP work has mainly focused on identifying gaps and obstacles in obtaining information about the chemical composition of manufactured products. In 2015, the Chemicals in Products Programme was created in support of the CiP work. It outlines the scope for disclosure, within and outside supply chains, and the supplementary documents provide information on existing industry models for disclosure. Unfortunately, very few stakeholders joined the CiP Programme. Basically, the work with the Programme has not progressed as expected.
The independent evaluator of SAICM 2006-2015 noted that although some progress in the work with the Emerging Policy Issues and Other Issues of Concern have been achieved, it is mainly limited to information collection and few concrete risk reduction measures.
In 2020 UNEP made its own assessment of the Issues of Concern (the new collective word for Emerging Policy Issues and Other Issues of Concern in the Intersessional Process) and concluded that the ambition level in the work with them must increase.
With among other things reference to the independent evaluator, and now also to the conclusion in the UNEP 2020 report, the NGO group has proposed criteria for evaluating when voluntary work in SAICM with the Emerging Policy Issues and Other Issues of Concern is insufficient and should be considered for elevated obligations outside of SAICM. The criteria were first presented in connection with an Intersessional Meeting in 2019 (the IP3 meeting), and updated in 2020 (for the purpose of the now postponed IP4 meeting). Complementing the criteria are two cases for how they relate to CiP, the first from 2019 and the second from 2020.
In the 2020 version of the CiP case paper, the basic concept for a global transparency standard was outlined. It has also been fed into the discussions for on targets, indicators and milestones for the updated UN chemicals strategy. The standard could be used as voluntary tool to progress the national CiP implementation work, but should ideally be binding from the beginning. More details are in the White Paper.
This is not an entirely new idea
In the chemicals regulation of the European Union – REACH – the first list of so called Substances of Very High Concern (SVHC) was published in 2008. A public transparency requirement is connected to the listing of chemicals to the SVHC list. Originally it stipulated that any stakeholder could request a retailer or manufacturer to disclose if an SVHC chemical is present in a product (disclosure concentration 0.1% for any component of the product). Disclosure had to be done within 45 days from the request. From 2021, all companies placing products, including waste for secondary raw materials, on the EU market must disclose this information in connection with registering their products/materials with the EU Chemicals Agency ECHA. The registered information will be in a public database to be operational later in 2021.
In 2013, the parties of the Stockholm Convention decided that the flame retardant HBCDD should be disclosed in insulation materials from recycled plastics.
In 2015, the Chemicals in Products Programme was established to support the work with the emerging policy issue Chemicals in Products within the frames of the UN chemicals strategy SAICM. It is a voluntary disclosure system, with the aspirational goal of full information disclosure for the chemical composition of a manufactured products (excluding cleaning products and personal hygiene products), within and outside supply chains. The Programme prioritises chemicals with the following hazard properties: persistent, bioaccummulative and toxic (PBT), very persistent, very bioaccummulative (vPvB) chemicals, carcinogens, mutagens, and chemicals toxic to reproduction (CMR), endocrine disrupters (EDC), chemicals toxic to the nervous system, and other chemicals of concern. These hazard properties correspond to those in the criteria underlying the EU SVHCs.
Now is the time to build on the most progressive provisions of previous initiatives, building on lessons learnt and responding to identified challenges. An integrated approach to information disclosure on chemicals in products will help achieve effective risk reduction for chemicals of concern. This is what the proposed GMTS is trying to achieve.