What is the corporate chemicals policy?
The corporate chemicals policy describes the guiding principles of for using chemicals and managing potential risks from their use. Based on an analysis of the status quo, it sets areas for improvement and defines measurable goals and timelines for their achievement. The chemicals policy is the very basis of corporate risk management and gives provides orientation for priority setting and decision-making.
Why have a corporate environment or chemicals policy?
The environmental policy is a document in which the organisation’s top management defines the direction of its activities aimed at limiting negative impact on the environment. Through the environmental policy, the organisation’s top management communicates its approach and aspirations with regard to the environment to interested parties.
For internal stakeholders (e.g. employees), the policy should indicate how to deal with cases in which more detailed regulations are not available. In relation to external stakeholders, the environmental policy is a declaration of will and specific obligations in the field of environmental protection.
You can either develop a standalone chemicals policy for your company or integrate it into the existing overall or environmental policy (e.g., in line with the EU Environmental Management and Auditing Scheme (EMAS) or the international ISO 14000 standard on environmental management systems).
With regard to the management of chemicals, the main and overarching goal to be included in the environmental policy should be the minimisation or at least continual reduction of negative impacts from the use of chemicals.
This can be specified further by, developing measurable goals in key focus areas:
Step-by-step development of a company policy
Conduct a self-assessment of all relevant business areas.
Knowledge about the status quo will create a solid information base for planning and decision-making. At a minimum, the self-assessment should provide information on the following items:
- Types of chemicals used: list volumes of substances per classification, total volume of SVHCs, types of products containing hazardous chemicals (by type) etc. The chemicals inventory (link) can be used to compile statistical information about the use of chemicals in products.
- Overview of legal requirements and future developments regarding chemicals, e.g. forthcoming restrictions, regulatory priorities, and trends.
- Purchasing criteria and routines, problems identified with suppliers and input materials.
- OSH and environmental management: chemical-related problems in the production, permitting, storage etc. If available, costs of waste treatment, emission abatement and workers protection.
- Products: overview of the types of products and their content of hazardous chemicals.
- Sales: sales statistics, including tends, overview of main markets and customers, their demands etc.
Use the self-assessment questionnaire and review data from the chemicals inventory to identify current practices, gaps, and risks.
Identify the key people who should be involved and establish a cross-functional Chemicals Policy working group.
Collaboration of this kind can be highly effective, driving improvement processes across multiple areas—including communication, competencies, and information management—ultimately leading to more efficient cooperation within the company.
| Core working group members | Role |
| Top management representative | To ensure the resulting policy has the full backing of top management, is realistic and economically feasible. |
| Legal advisor | To ensure that information about (future) regulation is considered. |
| Technical staff responsible for production | To ensure that a realistic perspective on options for change and limitations regarding equipment, process design and space. |
| Product / Quality manager | To ensure product safety and potential limitationsfor change are considered in the context of goal setting. |
| Staff responsible for environmental and occupational safety and health (OSH) management | To ensure that any existing challenges in environmental and worker protection are considered from the beginning and potential synergies are identified. |
| Salesperson | To ensure customer demands and “no-go’s” are wellrepresented in the discussions. |
Define overall aims
The overall aim of your company should generally consist of providing products and services that are of high quality and do not cause harm to human health or the environment.
Making a respective and company-specific statement at the start of your policy communicates insight into your company’s motivation to work on chemicals and thus frames all subsequent statements and goals.
Define mesurable goals
Base the development of specific goals on the overall policy and an evaluation of which business areas and activities are of highest priority and/or most relevant to address (first).
If necessary, additional information may have to be collected on the current situation if the initial self-assessment is not sufficient for specific aspects.
It may be useful to start the chemicals policy with only a few but quickly implementable goals to get started and to increase the level of ambition and the variety of goals over time. This way, you give the company time to learn and develop the system over time.
Safe products
As a formulator, the safety of your mixtures should be the focal area for chemicals management. Intrinsic safety, i.e. the absence/reduction of hazardous (classified) chemicals in your mixtures should be the main goal, which can be quantified in different ways. In the (public) company policy, you might state in more general terms, which chemicals, e.g. SVHCs, you aim to phase out on the candidate list.
Examples of quantified goals:
Currently, 25% of our mixtures contain at least one per- and polyfluorinatedalkyl substance (PFAS). By 2030, we will have phased out the use of all PFAS, i.e. all mixtures will be PFAS free.
Currently, 75% of all consumer mixtures contain skin sensitisers, mainlybiocides to preserve the products. By 2027, we will have found non-hazardous alternatives, and consumer mixtures will no longer contain any skin sensitizers.
By 2027, the company will reduce the use of SVHCs by 50% (by volume) inmixtures for professional / commercial use.
Every year, the restricted substances list is reviewed and amended in thelight of new scientific information about the substances we use (or intend to phase out).
If the use of (some) hazardous chemicals cannot be avoided, the company’s goal could be to ensure their safe use by providing mixtures in a form that prevents exposure and/or by providing good information and support for their safe use. This is normally only an option for professionally used mixtures.
Examples of quantified goals:
By 2028, all solid mixtures will be provided in forms (pellets, containers with dispensers etc.) that prevent dust formation at the workplace.
By 2027, we will review usage instructions of all mixtures for professional applications and provide specific, high-quality information about how they should best be handled and disposed of to minimise exposures.
By 2028 we will provide safety gloves together with all products requiring skin protection during use.
We will provide training in the professional use of all mixtures containing carcinogenic, mutagenic and/or reprotoxic substances (CMRs).
Safe production
In addition to ensuring safe products, preventing emissions from the company’s own production facility could be included as a company goal. Safe production could mean reducing the use of hazardous processing aids, reducing emissions to the workplace or the environment by organisational or technical means or reducing worker and environmental exposures by technical means or personal protective equipment.
Examples of quantified goals:
By 2028, our processing aids will no longer contain any endocrine disrupting chemicals.
By 2030, none of our processing aids is classified as CMR.
By 2027, all production processes are contained, and dosing systems are fully automatized.
By 2027, all workplaces will have been reviewed regarding minimizingby-stander exposures and eliminating (unnecessary) manual tasks.
By 2028, all exhaust gases collected via local exhaust ventilation will becleaned by absorption and recovery technologies or, where recovery is notpossible, incineration.
Transparency and information
Providing information and being transparent about the use of chemicals is another important area of chemicals management, which could be included in the chemicals policy.
Examples of quantified goals:
We have internal procedures in place to reply to customer queries aboutchemicals. Any query will be answered within one week.
We provide information about all hazardous ingredients in consumer mixtureson the packaging to enable consumers to make informed decisions.
We disclose the full composition of our mixtures to our customers.information may be kept confidential for a maximum of 10% (w/w) of the mixtures.
We ask all our suppliers to test and document compliance with legal restrictions, as well as our company-specific restricted substances list.
We provide full transparency about our business activities by publishing annual figures of production volumes by mixture type.
We support consumer decision-making by using eco-labels for all products that fulfil the eco-label criteria.
Research and innovation
If products or processes should be changed to reduce the impact of hazardous chemicals from a company, research and development activities are inevitable.
Examples of quantified goals:
We will spend 5% of our annual turnover on finding alternatives for SVHCs in our products.
Any reformulation process of our products will include an assessment of whether the most hazardous component could be replaced with a less hazardous alternative.
By 2030, the research and development (R&D) department will test and/or develop tools to assess the sustainability of mixtures and use it in their activities. The development of new products will exclude the use of endocrine disrupting chemicals.
Our R&D department will be involved in sector activities to substitute hazardous chemicals in our products.
Define monitoring and review
Monitoring and reporting on the implementation of a chemicals policy is a critical component of its success. This section can be brief, outlining how frequently progress toward goals will be assessed and how the company will communicate results.
It is advisable to define clear indicators of success, determine how goal achievement will be measured, and establish data collection routines to support consistent monitoring.
Tools and links
- Self-assessment questionnaire on chemicals risk management.
- The chemicals inventory (link).
- The organisation bizNGO provides a Chemicals policy template, with similar elements but a slightly different structure for presenting the chemicals policy.