Substitution of hazardous substances
Substitution means eliminating or replacing hazardous chemicals in products with less hazardous or non-chemical alternatives. The aim of substitution is to make products safer in terms of human health and the environment.
What is substitution?
Substitution means eliminating or replacing hazardous chemicals in products or processes with less hazardous or non-hazardous substances. It may also involve using non-chemical alternatives, other materials, new techniques or other processes. A key term within substitution is chemical or technical function, which refers to the function of the substance in the material, product or process. Defining the substance’s function in a specific application usually makes it easier to identify viable alternatives.
Strive for “functional substitution”
When substituting a substance, you should consider substances that can perform the same function as the substance you want to replace, rather than substances that have a similar chemical structure. This reduces the risk of "regrettable substitution", which means substituting one substance for another substance with similar properties. Searching for substances with the same technical function can broaden the range of possible alternatives that are available, as this approach also opens up for alternative technical solutions.
The aim of substitution is to phase out hazardous substances or replace them with less hazardous alternatives for safe handling during manufacture, use and waste management/recycling.
It is sometimes necessary to phase out certain substances because they become restricted or prohibited by law. It may also be a question of meeting customer demands for safer products that are better for human health and the environment. It is possible to stay ahead of legislation and phase out or substitute substances which are hazardous, but not yet covered by any regulations. This is particularly desirable in the case of products that could entail high or long-term exposure for humans and/or the environment.
Who can substitute?
Companies that manufacture articles, materials or chemicals are responsible for substituting any hazardous substances in their products. Businesses that handle articles, materials and chemicals also have the same responsibility.
Companies that purchase articles or products for resale have a responsibility to ensure that the articles comply with applicable legislation and do not contain prohibited substances. Retailers can also go further than the law requires and strive to eliminate more hazardous substances from their articles or products. This can be achieved by requiring suppliers to substitute hazardous substances with safer alternatives. It is also possible to choose another supplier if this requirement is not met.
If you in your profession purchase articles and/or products to be used in a business, you should look over whether the articles contain any hazardous substances. This can be done by asking your suppliers what the articles contain and impose a requirement that hazardous substances must not be used if safer alternatives are available. It is often better to impose requirements regarding chemicals as soon as you start purchasing articles.
What needs to be substituted?
You should ideally substitute all hazardous substances as a preventive measure in order to reduce the risk of adverse effects on human health and the environment. According to the substitution principle described in Chapter 2 Section 4 of the Swedish Environmental Code, chemicals which can be expected to pose a risk to humans and the environment must not be sold or used if it is possible to substitute them with products that can be assumed to be less hazardous.
Hazardous substances in chemical products or mixtures must always be classified and labelled in accordance with the CLP Regulation. This ensures that it is possible to find out what substances in chemical products are harmful and in what way they are hazardous, e.g. whether they pose a physical, health-related and/or environmental hazard.
We recommend that you prioritise substituting the most hazardous substances first, that is substances that fulfil the criteria to be considered as Substances of Very High Concern (SVHC) in the EU’s REACH Regulation and/or the so called “particularly hazardous substances” in accordance with the Swedish environmental quality goal A Non-Toxic Environment. The substances that have so far been identified as SVHC are listed in the Candidate List in the REACH Regulation.
In PRIO – a tool for substitution, we use the criteria for SVHC in REACH and for ‘particularly hazardous substances’ in the environmental quality goal A Non-Toxic Environment and refer to them as ‘phase-out substances’. In PRIO’s database, we list a series of substances which fall for these criteria. Some examples of the hazardous intrinsic properties of phase-out substances are:
- carcinogenic, mutagenic, toxic to reproduction substances, known as CMR substances, category 1A or 1B
- persistent, bioaccumulative and toxic substances, known as PBT substances,
- very persistent and very bioaccumulative substances, known as vPvB substances
- endocrine disruptors.
If you are responsible for many products, you should start by identifying the product applications that result in high or long-term exposure of humans or the environment.
How to substitute?
The process of substitution can be illustrated as a staircase consisting of five steps, where each step builds on the previous one.
The steps in the substitution process
- Gather information on chemicals used
- Identify unwanted substances
- Find available alternative substances or new technical solutions
- Evaluate and select alternative substances or technical solutions
- Develop new alternative chemicals or technical solutions
1. Gather information on chemicals used
A prerequisite for substituting hazardous substances is to prepare an inventory of chemicals being handled by your company. This could be substances which are present in products or waste products after manufacture, or substances which are used in manufacturing processes.
2. Identify unwanted substances
The second step in the process involves identifying substances to substitute. If your company does not manufacture articles or products, but are an importer of articles, the request specifications you impose on your suppliers will be your primary tool in the substitution process.
3. Find available alternative substances or new technical solutions
The third step in the substitution process involves drawing up an inventory of available alternatives to identify substances with an equivalent function. This could entail finding other chemical or non-chemical alternatives, materials or other technical solutions. This could for example be a question of substituting material A with material B because material B does not require a particular additive, which has hazardous properties.
4. Evaluate and select alternative substances or new technical solutions
The fourth step requires that you have collected sufficient information in order to compare and assess the alternatives, so that you can select a substitute for a particular application. Identifying a substitute can be a knowledge- and resource-demanding process. Key considerations which you should take into account are the hazardous properties of the substitute, relative exposure (e.g. compare the difference in total exposure between the current substance and the substitute), technical performance, Life Cycle Assessment (LCA) and cost.
5. Develop new alternative substances or new technical solutions
The fifth step in the substitution process involves developing new sustainable substances or techniques. In the absence of suitable and available alternatives, new innovations and/or techniques may be necessary. In this case, the companies are responsible for driving development.
When a new substance or technique is developed, it has to be applied, improved and further communicated within the supply chain.
Guidance and support in the substitution process
Ask the Swedish Chemicals Agency
If you work in a company, as an inspector or if you are a private individual and have questions concerning the legislation and which substances must be substituted, you can contact our helpdesk service Ask the Swedish Chemicals Agency Helpdesk.
PRIO – a tool for substitution
PRIO is a web-based tool for companies and government agencies to use in identifying hazardous substances that can be substituted. PRIO was developed by the Swedish Chemicals Agency.
PRIO is a tool for those wanting to work proactively to reduce the risks associated with the use of hazardous substances. The tool gives support in the second step of the substitution process e.g. to identify unwanted substances. Amongst other things, there is a database containing more than 10.000 examples of hazardous substances that should be phased out or prioritised for risk reduction. The substances are divided into two levels: phase-out substances and priority risk-reduction substances. The criteria for determining what are considered to be phase-out substances in the PRIO database are the same as those for substances of very high concern (SVHC) in the REACH Regulation’s, but there are also substances included which are linked to the Swedish national environmental goal A Non-Toxic Environment.
Guidance on how to determine safer alternatives
The Organisation for Economic Co-operation and Development (OECD) has published a guidance on the recommended minimum requirements for assessing if the chemical alternative is safer from a health and environmental perspective than the chemical prioritized for substitution. The requirements constitute the first part of a process called Alternatives Assessment and cover the safety aspect of a chemical. The process Alternatives Assessment is a methodology developed to make informed decisions to avoid regrettable substitutions.
The website of the European Chemicals Agency (ECHA) provides more information on how to approach substitution systematically. The website also contains information on the European networks and workshops for collaboration relating to substitution for companies in the supply chain.
Centre for Chemical Substitution
The Centre for Chemical Substitution is located at the Research Institutes of Sweden (RISE) and is responsible for promoting and raising awareness of substitution. The centre has an advisory role with a helpdesk function addressing small and medium-sized companies in particular for guidance in their work on substitution. The centre offers training for companies and others wanting to learn more about substitution and promote substitution work through collaboration and exchanges of knowledge among the stakeholders.
The centre’s advisory function focuses primarily on the third and fourth steps in the substitution process: searching for alternative substances or other technical solutions, and assess and select substitutes. In step two, companies can get help to prioritise substances for phase-out based on the company’s own knowledge of the substances they use. By mediating contact with developers and researchers, the Centre for Chemical Substitution can also play a role in step five.
SIN List and Marketplace
The International Chemical Secretariat (ChemSec) is a non-governmental organisation which offer a range of services which may be useful for anyone wanting to work on substitution. SIN List and Marketplace are two of these services.
SIN List is a database containing substances which, according to ChemSec, meet the criteria for being considered substances of very high concern, known as SVHC, according to REACH, but which are not currently covered by the legislation. SIN List can be used as guidance for anyone seeking to go further than the statutory requirements and phase out hazardous substances.
The web-based tool Marketplace is a website for promoting safer alternatives to hazardous substances which are currently being used on the market. It can act as a source of support in finding alternative substances, materials and techniques (step three of the substitution process). The tool is aimed at buyers and sellers of environmentally friendly alternatives or techniques.
There are also industry-specific initiatives in the form of tools, labelling systems or positive lists that are intended to guide companies in their efforts relating to substitution. You can always contact your industry organisation for guidance and advice.