Do I have to substitute?
As a result of gathering data on the impact of a chemical on human health and the environment, you may conclude that you could reduce the risk caused by your substance.
That knowledge in itself may drive you to look for safer alternatives.
However, for the most hazardous substances, the EU legislation can require you to substitute them.
Legal requirements bring new opportunities
Over time, the most hazardous substances are being identified under REACH as substances of very high concern. Those substances can subsequently be subject to legal requirements to manage the risks they pose. It is essential to follow how your substances are being regulated, for example, whether they have been identified as substances of very high concern or whether there are proposals to restrict them or to require prior authorisation before they can be used. In that way, you can identify the likelihood of them being subject to more stringent legal requirements and you can start preparing in time.
Anticipating the legal requirements is a smart strategy. Better and safer alternatives may already be available, and they can open new opportunities for your company. Finding out the properties of potential alternatives is easier now, as more information is available. Data gathered on substances is available on ECHA's website to help you make informed choices.
Substitution in other legislation
Substituting hazardous chemicals is also part of the Biocidal Products Regulation. The regulation excludes the use of some hazardous substances. It also requires products containing substances which are candidates for substitution to be assessed in comparison with similar available products. This may lead to restriction in the authorisation of the biocidal products.
The EU Workers' protection legislation also places obligations on employers. Where possible, employers should replace hazardous chemicals with chemicals or processes which are less – or not at all - hazardous.