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.