Guide Sustainable Chemicals

GUIDE ON
sUstaINablE
chEmIcals
A decision tool for substance manufacturers, formulators
and end users of chemicals
CONTENTS
page 2-7 page 8-33 page 34-37 page 38-39 page 40
1.0
Introduction: Sustai-
2.0 3.0 4.0 5.0
nable chemicals – yes Criteria for selecting
- but how? sustainable chemicals Golden rules Outlook Literature
page 4 page 5 page 11
Substance-specific cri-
Why sustainable Integration of “new” teria for the evaluation
chemicals? issues of sustainability
page 4 page 5 page 24
Use-specific criteria
Why another Contest and structure for the evaluation of
guide? of the guide sustainability
page 5 page 6 page 41 page 42-47
The result of using

AB AX
Target Group the criteria Abbreviations Annexes
2 GUIde On SUSTAInAbLe ChemICALS
GUIde On SUSTAInAbLe ChemICALS 3
1.0
Int
Sustainable chemistry comprises of many aspects. They range

from the selection of inherently safe chemicals via the assess-
ment of environmental impacts of product lines by lifecycle ana-
lysis to the implementation of ambitious social standards in the
supply chain.
Neither today nor in the future, may sustainable che- 1.2. Why ANOThEr guidE?
micals have unacceptable (eco-) toxic impacts on man Several approaches already exist regarding the imple-
and the environment. They may not or only insignifi- mentation of sustainability as such. A good overview
cantly contribute to the depletion of natural resources. is provided in the background paper of the German
Furthermore, they may not cause or enhance socially Environment Agency on sustainable chemistry1.
precarious situations or unhealthy workplaces, howe-
ver they are beneficial to the entire economy and to Numerous practical examples have been published on
enterprises. the implementation of single aspects of sustainability
in enterprises2. However, up to now guidance suppor-
The sustainable use of (sustainable) chemicals aims at ting enterprises in a systematic manner to practically
providing socially necessary products while mini- implement sustainable chemistry in their daily practice
mising resource consumption, reducing substance is missing.
losses and controlling exposures by corporate, design
oriented, organizational and technical means and at This guide assists the selection of sustainable chemicals
the same time enhancing healthy workplaces and fair by providing criteria to distinguish between sustainable
social conditions. and non-sustainable substances. It can also support a
more sustainable use of chemicals, by highlighting sin-
1.1. Why SuSTAiNABlE ChEmiCAlS? gle aspects of the evaluation. The guide is not specific
The selection of sustainable chemicals can have advan- to certain industry sectors, but the criteria can be used
tages for the protection of workers, consumers and the across all fields of economy.
environment. In the long run, sustainability leads to
more innovative uses of chemicals and is therefore also Here we want to mention an additional approach: the
economically attractive. Hence, a sustainable product HACCP-concept (“Hazard Analysis and Critical Control
is a product that is successful on the market, for which Point”). It is implemented for managing risks along sup-
less dangerous substances are used and which have less ply chains, mainly in the food industry, but can also be
adverse impacts on the environment and to the society used to prioritise risk management in other sectors3.
than a comparable product.
4 GUIde On SUSTAInAbLe ChemICALS

1.3. TArgET grOup addressed to a minor extend only. Such aspects are
This guide is addressed to manufacturers, formulators treated in detail within the socio-economic analysis de-
and end users of substances and mixtures. It supports veloped under REACH. It is introduced in chapter 2.2.6.
the integration of aspects of sustainability in their
selection and the way chemicals are used. In this guide, the term “chemicals” means both
substances and mixtures. The evaluation of sustaina-
Chemical end users frequently demand specific techni- bility, in particular regarding the substance-specific
cal standards of the products they use (substances and criteria is recommended to be performed primaril for
mixtures), like the uniformity of coloration achieved substances as such. However, along their lifecycle they
by a specific dye or a particular degree of light resi- are in most cases included into mixtures (formulation)
stance of lacquers. In addition, requirements of workers’ and either consumed or further processed into articles.
protection, consumer protection and environmental This is reflected in the second set of criteria addressing
protection must be fulfilled. The consideration of su- the uses.
stainability aspects may trigger further demands, e.g.
on conformity of actors in the supply chain with social Formulators and end users of chemicals (= substances
standards. and mixtures) normally handle mixtures rather than
substances. In this case we recommend to start the
Some enterprises have already implemented a sophi- assessment of the mixture with substances of the
sticated quality or environmental management system mixture classified as dangerous. These substances are
and are eager to substitute dangerous chemicals. Howe- important for occupational health and environmen-
ver, small and medium sized enterprises (SMEs) normal- tal protection in companies. They are documented in
ly have only little or no experience in the selection of section 3 of the safety data sheet of the mixture (in
sustainable chemicals. The guide aims particularly to most cases, for substances which are not classified as
support these companies. dangerous the downstream user has no information on
their properties (without a specific communication with
1.4. iNTEgrATiON Of “NEW” iSSuES his supplier5).
For some aspects (e.g. avoiding chemicals with a high
human toxicity) well defined decision criteria can be This guide consists of six chapters. The criteria for
provided in this guide (e.g. classification as canceroge- sustainable chemicals are introduced in Chapter 2,
nic, mutagenic or reprotoxic of categories 1, 2 and 3). following this introduction. Substance-specific criteria,
which only depend on the substance properties, are
For other aspects these criteria don’t exist yet, for ex- differentiated from use-specific criteria, which depend
ample on resource consumption, reduction of green- on the type of its application and use.
house gas emissions and taking social responsibility. In
many industry sectors “best available techniques” have The criteria in this guide are selected according to two
been compiled in so called BREF documents which guiding questions:
will lead to resource savings and emission reduction if > Which criteria can be applied by enterprises in prac-
implemented4. tice for the selection of substances and mixtures?
> What types of demands can enterprises pose their
The evaluation of sustainability of chemicals is more suppliers that exceed those of product labels such as
than the traditional identification of dangerous sub- the Blue Angel?
stance properties, assessing exposures and characteri-
sing risks. Therefore, this guide also provides support Following the description of the sustainability criteria,
for the “new” issues – even though no fully developed in Chapter 3 “ten golden rules” for the selection and use
and quantified criteria are available. of sustainable chemicals are introduced, which
can be understood as simplified and aggregated sustai-
Demands for sustainable chemicals can be better nability criteria. The “ten golden rules” relate
accommodated (maybe even only then!), when they are to the selection of sustainable chemicals connected with
integrated not only into a company’s policy and goals some important rules regarding their safe application.
but also in its quality or environmental management sy-
stem (including standards for success monitoring). The In Chapter 4, the results and consequences of an evalu-
implementation is normally a step-by-step process. ation are illustrated using two examples and an outlook
on future developments is given. Chapter 5 provides
1.5. CONTENTS ANd STruCTurE Of ThE guidE references used in this guide and abbreviations are
This guidance sets the focus on potential impacts of explained in Chapter 6. The annexes contain links and
substances on man and the environment and on social further information sources on substance lists, specific
responsibilities in supply chains. Economic aspects are criteria, data bases and assessment systems.
GUIde On SUSTAInAbLe ChemICALS 5

1.6. The resulT of using The criTeria application, not cause any harm. Other aspects, such as We recommend a stepwise approach:
1.0 This guidance does not aim to give an assessment very high benefits of the use of a substance may justify
method resulting in figures of sustainability. This seems the continuation of its use, although it was originally 1. For the first assessment data should be used which
not to be appropriate regarding the complexity of the evaluated as non-sustainable. are readily available in the company. The resulting
issue. However it describes criteria which can be used sustainability profile (see chapter 2.1.9) indicates areas
for a first assessment of the sustainability of substances Figure 1 illustrates how the substance-specific and the which require further action.
and mixtures. use-specific criteria are interlinked.
Chapter 2.2 describes consequences of the application 2. In the next step further information is included. It
When analysing the sustainability of chemicals using of the substance-specific criteria for the next step of might become necessary to use additional data sources.
the following, substance-specific criteria will result in the assessment, the application of the use-specific Some of them are described in Annex 4.
any one of the following statements: criteria.
> No action is needed, because available information
indicates that the chemical is not “problematic” Chemicals without problematic properties, which can
(green) be regarded as inherently safe will not be available in
sources:
> No action is needed, because the available informati- all cases. Nevertheless, there may be ways to optimize 1 http://www.umweltbundesamt.de/uba-info-medien/mysql_medien.php?a
nfrage=Kennummer&Suchwort=3734
on indicates problematic substance properties (yellow) the use of problematic substances, for example by 2 For example the implementation of environmental or quality manage-
> There is a high priority to act, because the available implementing risk management measures. The guiding ment systems, the manufacture of substances using catalysts (energy
and resource savings), design for the environment integrating recycla-
information indicates very problematic substance questions are: bility of products (reduction of material losses), the self-commitment to
“codes of conduct” which exclude dangerous substances from products
properties (red) and reclaim compliance with workplace standards along the supply
> There is a need to gather further information, becau- > How can the emission potential of a specific use be chain.
3 http://www.bfr.bund.de/cm/234/fragen_und_antworten_zum_hazard_
se no or little data is available (white) minimized? analysis_and_critical_control_point__haccp__konzept.pdf.
4 http://eippcb.jrc.es/reference/
> Which user groups will be exposed to the chemical?
5 In case of mixtures consisting of many substances in a first step it should
The application of the use-specific criteria can modify > How can exposures be reduced? be clarified, which substances as lead substances are triggering the risk
management measures fort he mixture. Guidance for the identification
the evaluation of a substance’s sustainability judged of lead substances is given in Part III of the REACH Practical Guide on
only by the substance-specific criteria, because proper- Related support is provided in Chapter 2.2 (use-specific Exposure Assessment and Communication in the Supply Chains (http://
www.cefic.org/Files/Publications/Doc-1-Part-1-to-3-Practical-Guidance-
ties assessed as problematic may, due to the type of criteria). final.pdf).
figure 1: inTerlinks beTween criTeria
6 Guide on sustainable chemicals Guide on sustainable chemicals 7

8 Guide on sustainable chemicals
Guide on sustainable chemicals 9
2.0
Criteria for seleCting
sustainable ChemiCals
The criteria for the selection of sustainable chemicals should

enable companies to systematically implement sustainable
chemistry in their daily practice.
Generally, substance-specific criteria which only depend application of the use-specific criteria to chemicals
on the properties of a substance, and use-specific evaluated as “red” and “yellow” may be helpful in the
criteria which mainly depend on the type of its use, prioritising of action needs. For chemicals which have
are distinguished. The substance-specific criteria are been evaluated as “white”, more information should be
introduced in Chapter 2.1 and the use-specific criteria obtained as a priority action to enable the assessment
in Chapter 2.2. of the substances-specific criteria.
The evaluation of sustainability is based on the fol- Figure 2 gives an overview of the possible options to act
lowing eight substance-specific criteria (step 1). The on, depending on the result of the evaluation.
figure 2: options to aCt depending on the results of the evaluation
cRiteRia Red YelloW GReen White
substance on list substitution
dangerous Pc Properties substitution Risik management
use-specific criteria
human toxicity
Priority “red” > substitution
GatheR inFoRmation
mobility
Priority “yellow” > substitution
no action need
dangerous for the environment

or risik management
substitution, design
Greenhouse potential
increasing material efficiency
substitution, design
Resource use
increasing energy efficiency
Request standards from sup-

origin of raw materials plier or change sourcing

2.1. SubStance-Specific criteria for the evalu- > Green: there are no indications of critical properties,
ation of SuStainability no action needed,
For the evaluation of sustainability of chemicals, the > Yellow: there are indications of problematic pro-
following eight substance-specific criteria should be perties; further analysis with use-specific criteria is
used as a first step: necessary,
1. Mentioning in lists of “problematic substances” > Red: the substance is obviously problematic. Sub-
2. Dangerous physico-chemical properties stitution possibilities should be assessed with high
3. Human toxicity priority,
4. Problematic properties related to the environment > White: Information is not sufficient for an evaluation.
5. Mobility Further information should be gathered.
6. Origin of raw materials
7. Emission of greenhouse gases Some criteria consist of several sub-criteria. Here, the
8. Resource consumption overall evaluation results from the integration of all
sub-criteria into one. The sub-criterion with the worst
In the following paragraph, these eight criteria are de- evaluation determines the overall result (results are not
scribed. The relevance of the criteria regarding human averaged!). The sequence of “severity” is:
health, the environment, society and the economy is
explained as well as their applicability. Additionally,
possibilities to obtain information on certain aspects
are discussed.
R
Some products require properties which automatically
result in an assessment as being “less sustainable”. E.g.
can preservatives are used to prevent microbial degra-
dation of lacquers. This requires a biocidal activity of The action requirement is highest for red and lowest
ingredients which are hazardous to the environment. for green. In case of “White” a high need for further
In such cases a problematic property has to be accepted action is required to get sufficient information for the
to achieve the required function of the product. assessment.
If criteria refer to properties which are essential for the Note: The assignment of colours and indicators to the
function of the product, it might be that these criteria criteria is a proposal of the editors, which is based on
become less important for the overall assessment of the the expertise of the persons involved.
product.
If the function of a product requires problematic

properties, it should be carefully checked whether it
is possible to achieve the same function by a different
product design. This includes alternative solutions
without chemicals, e.g. constructive solutions for flame
protection. In any case – including alternative solutions
without chemicals – the assessment of the alternative
solutions has to cover the different potential impacts
on man and the environment (e.g. energy consumption
in case of vegetation control using heat). Details on the
assessment of substitutes are given in chapter 2.2.5 of
this guidance.
The sustainability of chemicals based on their intrinsic

properties is evaluated using tables with specific indica-
tors, which are included at the end of each section. To
improve understanding, the colours “green”, “yellow”,
“red” and “white” are used to indicate the evaluation
result. The following explains what each colour means:

2.0 exkurSuS:
in the past, much substance-related empirical data has been generated for assessing risks and
classifying and labelling substances. this data, which was and is required among others in le-
gislation on supply chain communication, is an important information basis for the evaluation
of a substance’s sustainability. in general they are communicated with the safety data sheets.
therefore, some of this data is explained in annex 5.
2.1.1. Mentioning on lists of problematic substances Applicability of criterion

Substances with particularly dangerous properties for The criterion is applicable to any substance. The use of
man and the environment may already be regulated in these lists should be easy as soon as the CAS numbers
different contexts (e.g. legislation or conventions, such of the substances have been identified. If mixtures are
as the Helsinki or Stockholm Convention). Corporate assessed, each (known) component in the mixture should
instruments may exist for managing these substances be checked if it is listed.
as well, such as the “Global Automotive Declarable
Substance List”6 of the automotive industry. Legislation, Information basis
conventions and private instruments may contain lists The recommended lists are publicly accessible. As some
of substances to which they refer. If substances are in- of them are regularly updated, no current summary of
cluded in any of these lists, it is a strong indication that the lists is provided. Links to the web pages are com-
it is not sustainable. piled in Annex 1.
Unfortunately, there is not “the one and only”, but Evaluation

several lists exist. For the evaluation of sustainability Substances are only included in lists of problematic
of substances we recommend to use the following lists. substances, if they have been assessed by experts as of
They origin from European or international regulations particular concern. It is to be noted that the lists are
and conventions. They have been thoroughly discussed developed for a particular purpose (e.g. environmental
by experts and politically agreed. protection) or from a particular perspective. Therefo-
> The candidate list for authorisation under REACH, re, certain properties may dominate whether or not a
> The list of priority and priority hazardous substances substance is included and consequently, the lists are not
of the Water Framework Directive complete regarding sustainable decisions.
> Persistent organic compounds regulated under the
POPs-Convention The criterion “mentioning on lists of problematic
> Substances on the priority lists of OSPAR7 and HEL- substance” is evaluated using Table. “Red” and “yellow”
COM8 are not differentiated, because a substance can only be
> Substances affecting the climate according to the “listed” (=red) or “not listed” (=green).
Montreal- and Kyoto –Protocol
> Ozone depleting substances according to the Montre-
al protocol
table 1: uSe and evaluation of the criterion “MentioninG on
> Substances, for which marketing and use restrictions
SubStance liStS”
exist (REACH Annex XVII)
> List of endocrine disrupting substances. eValuation red Green
Substances are not mentioned here if they are discussed
criterion substance is mentioned substance is not mentioned
in the following chapters.
substance in one or more lists. in any list.
Relevance indicator substance lists

> For society: Toxicity – public health and integrity of (c.f. annex 1).
workers
Note: “White” should be given if the CAS number of the substance has
> For the environment: Ecotoxicity – Health of not yet been identified. In this case it is not possible to check clearly
ecosystems whether the substance is on the lists.

2.1.2. dangerous physico-chemical properties on of REACH, as a comprehensive data set is already
Substances with hazardous physico-chemical properties required for substances manufactured or imported in
are difficult to handle for workers. Alternatives with amounts between 1 and 10 t/a10. Users of substances can
less dangerous physico-chemical properties should be find information in sections 2, 9 and 10 of the pertai-
used or risk management measures implemented at ning safety data sheets. Additionally, public databases
workplaces, in order to prevent exposure and potential can be used, such as the “common substance data pool”
danger to workers. In addition, physico-chemical pro- (Gemeinsamer Stoffdatenpool von Bund und Ländern11)
perties could endanger installations (explosion, fire). or the data base on classification and labelling12. If the-
re are doubts on this information, substance manufac-
Relevance turers should be consulted.
> For society: Chemical risks at work
> For the economy: Costs for measures, risks to property Evaluation
In Table 2 dangerous physico-chemical properties and
Applicability of criterion indications of danger (R- und H-phrases) are assigned to
Some substances are used especially because of their categories.
(dangerous) physico-chemical properties; in these cases
the criterion is not applicable. For example, fireworks Remark
cannot be produced without the use of pyrophoric Particle size belongs to the physico-chemical proper-
substances9. ties. Nanoscale materials can be released from their
matrices during the waste phase. At present knowledge
Information basis is limited about the fate and the hazardous properties
Physico-chemical properties can be evaluated using a of nanoscale materials in waste treatment plants. This
substance’s classification. The necessary information refers especially to materials which are not easily degra-
should become available through the implementati- ded. Therefore, If possible such uses should be avoided.
Note: If information is missing to judge on this criterion,

table 2: uSe and evaluation of the criterion “danGerouS phySico-cheMical propertieS”***
the colour white should be assigned. This indicates that

evaluation red YelloW Green
criterion: substance is explosive, substance is flammable substance has no r-phrase

dangerous physico-chemical oxidising, very flammable or or only r-phrases between r1
properties pyrophoric and r19
information should be gathered.

indicator: e; r2, r313 F; r10, r11, r15 no r-phrase
c&l according to 67/548/eec* o; r7, r8, r9
F+; r12, r17
indicator: h200, 201, 202, 203, 205, 220, h 204, 221, 223, 224-22613, 252, no r-phrase
c&l according to 221, 222, 224-226)14, 228, 240, 272, 280, 281, 290
clP-regulation ** 241, 242, 250, 251, 260, 261,
270, 271
*: C&L according to 67/548/EEC, Classification and labelling according to Directive 67/548/EEC

**: C&L according to CLP-regulation: Classification and labelling of substances according to the European regulation on the classification,
labelling and packaging of substances and mixtures.
***in addition to table 2::

some r-phrases can be assigned only in addition to other classifications according to the “old” classification and labelling
rules (complementary labelling). the clP-regulation allows the independent assignment of these. if one or more of the r- or
h-phrases apply, a substance’s dangerousness is increased in the evaluation:
r1: explosive when dry – euh001
r6: explosive with or without contact with air– euh006
r14: reacts violently with water – euh014
r18: in use, may form flammable/explosive vapour-air
mixture – euh018
r19: may form explosive peroxides – euh019

2.1.3. Human toxicity For certain applications, substances are selected just be-
2.0 Substances which are toxic to human health are to be cause of their dangerous properties, e.g. active substan-
avoided in general, because they may cause harm to ces in biocidal products and plant protection products,
workers during handling and use as well as to consu- as well as pharmaceuticals. Here, the criterion cannot be
mers during the use of chemical products or articles. applied. However, the use of such substances should be
The substance properties, which may cause irreversi- critically reviewed.
ble and severe damage to human health, like cancer
or which may damage the immune system, are more Information basis
problematic than those which cause reversible and less The classification of a substance is normally sufficient
severe effects. Some properties are relevant not only for for the evaluation. Respective information can be found
human health, but also for adverse impacts they may in the safety data sheet (c.f. Annex 5) in sections 2 and
have on the environment (e.g. endocrine disruption). 11. Regarding endocrine disruption, lists can be used,
which have been developed in the context with the
Relevance European strategy on endocrine disrupting substances
> For society: Workers health and public health (c.f. Annex 1).
Applicability of criterion Evaluation

The human toxicity of a substance is an intrinsic proper- In tables 3 and 4 the indications of danger (R-phrases)
ty which can be viewed upon separately. However; the are assigned to categories (red, yellow, green). This
dangerousness to human health depends on the type assignment has been derived from the “Easy-to-use
of use of the substance and its mobility and emission workplace control scheme for hazardous substances”
potential (c.f. Chapter 2.1.5. and Chapter 2.2.1). If a (Einfaches Maßnahmenkonzept Gefahrstoffe, EMKG) of
substance is manufactured and used only under strictly the Federal Agency for Occupational Health and Safety.
controlled conditions (e.g. biocides to avoid bacterial It supports enterprises’ decisions on risk management
contamination of closed cooling circuits or lead sulphate measures to ensure safe use of substances and mixtures.
in car batteries), toxic effects to humans cannot be exclu-
ded, but are unlikely.
Table 3: Use and evalUaTion of THe criTerion “HUman ToxiciTy”15 – direcTive 67/548/eec
Note: If information is missing to judge on this criterion, the colour white should be assigned. This
evaluation red yellow Green
sub-criterion: substance may cause severe substance may damage health substance is not dangerous to
dangerous by inhalation, inge- health damage human health
stion & eye contact
indicator r26, 28, 32, 39/26. 39/28, 45, r20, 22, 23, 25, 29, 31, 39/23, no classification
classification according to 46, 48/23, 48/25, 49, 60, 61, 64 39/25, 40, 41, 42, 48/20, 48/22, “only” r36, 37, 65, 67
67/548/eec 62, 63, 68, 68/20, 68/22
sub-criterion: substance may cause health substance has only light effects
substance damages skin
dangerous upon skin contact damage if taken up via the skin on skin
indicator r35, r43 as well as r24 and r21, 24, 34, 38, 39/24, 40, no classification
indicates that information should be gathered.
classification according to r27, 34, 39/27 For skin-penetra- 48/21, 48/24, 68/21 For skin- “only” r66
67/548/eec ting substances16: r61 penetrating substances16: r62,
63, 68
sub-criterion: substance is on the list of endo- substance is a suspected endo- there is evidence that the
endocrine disruption crine disrupting substances crine disrupter substance is not endocrine
disrupting
indicator annex 1: links to substance lists substance is listed as suspected tests show the substance is not
substance list (endocrine disrupting chemi- edc, test results are ambiguous endocrine disrupting
cals, edcs)
overall evaluation

table 4: uSe and evaluation of the criterion “huMan toxicity”17– clp-reGulation
Note: If information is missing to judge on this criterion, the colour white

should be assigned. This indicates that information should be gathered.
sub-criterion: substance may cause severe substance may damage health substance is not dangerous to
dangerous by inhalation, inge- health damage human health
stion and eye contact
indicator: h300, 330, 340, 350, 350i, h 301, 302, 318, 330, 331, 332, no classification
classification according to clP- 360d, 360F, 37018, 372, euh032, 334, 341, 351, 361d, 361f, 371, “only” h304 319, 335, 336
regulation h 362 370, 372, 373
euh029, euh031
sub-criterion: substance may cause health substance damages skin substance has only light effects
dangerous upon skin contact damage if taken up via the skin on skin
indicator: h31419, 317 as well as h311 and h311, 312, 31419, 315, 37018, 371, no classification
classification according to clP- h310, 37018 373, For skin-penetrating sub- “only” euh066
regulation For skin-penetrating substances 16: h 341, 361f, 361d
stances20: h 360d
Gesamtbewertung
Remark: Relevance
If workplace exposure estimations have to be made > For the environment and economy: Damage to ecosys-
for the use of substances, appropriate estimation tools tems
should be used, e.g. the EMKG tool or the COSHH ap- > For society: Danger for human health via accumulati-
proach. The EMKG tool has been updated in September on in the food chain
2009. The new version includes the classification sche-
me according to the CLP regulation (BAUA 2009). Applicability of criterion
For some substances and mixtures persistency and high
2.1.4. problematic properties related to the environment aquatic toxicity are required for the function of the pro-
Substances, which are persistent, bioaccumulative and duct. Examples are biocidal products which are harmful
toxic (PBTs) or very persistent and very bioaccumulative for the environment. In these cases the criterion always
(vPvBs) are particularly relevant for the environment, indicates a low degree of sustainability. In addition,
because they: the PBT/vPvB criterion is not applicable for elements
because they acan not be degraded.
> Concentrate in the environment (persistence and
bioaccumulation) and in the long run may reach Information basis
concentrations above which adverse effects are likely Substances which have been registered under REACH and
to occur, exhibit PBT/vPvB properties have to be identified in the
> Are transported via the atmosphere and biosphere safety data sheet. Furthermore, information on persis-
and can be found far from their emission sources, tence, degradation, bioaccumulation and aquatic toxicity
even in pristine areas,; have to be provided in sections 9 and 11 of the SDS. Data
> Cannot be recovered, once they have been released to will increasingly become available in the context of regist-
the environment. rations under REACH21.
Furthermore, PBTs and vPvBs can accumulate in the Evaluation

food chain and damage human health. In table 5 dangers for the environment are assigned
to categories (red, yellow, green). For the evaluation
Beside PBT and vPvB substances, further substances of PBTs/vPvBs, the criteria of REACH Annex XIII are
are problematic for the environment, if they have the provided (c.f. Annex 2). If all criteria are fulfilled, the
potential to harm the environment on a local scale – or substance is a PBT/vPvB.
in case of poorly degradable substances – on a larger
scale. As criterion for these properties classification of Frequently, information on half-lives and on bioconcent-
substances as “harmful for the environment” is used. ration is not available. If there is a lack of data, estima-

tions can be performed using indicative criteria on the Substances classified as dangerous for the environment
2.0 degradability of a substance or its partitioning coeffici- can have the following R phrases resp. H classes: R50
ent for octanol/water (LogKow): Substances which are (H400), R5123, R5223, R50/53 (H400, H410).
inherently not degradable or are not easily degradable
(OECD screening test22) should be evaluated as persis-
tent. Substances with a LogKow > 4 should be evaluated
as bioaccumulative. It should be noted that these values
are only indications of dangerousness and not sufficient
for a classification as PBT or vPvB.
table 5: uSe and evaluation of the criterion “danGerouS for the environMent”
criterion: substance fulfils the Pbt/vPvb based on available information, no Pbt/vPvb, low aquatic
Pbt/vPvb and toxicity, data criteria24; information in sdb, it cannot be excluded that the toxicity.
availability that substance is a Pbt/vPvb is substance is a Pbt/vPvb. t25.
lc50 value.
indicator data on persistence and bioac- Pbt/vPvb there is evidence that the
substance information cumulation, toxicity and eco- aquatische toxizität: substance is not a Pbt/vPvb
from testing toxicity. substance is identified lc50 < 0,1 mg/l. and has no or a very low
as Pbt/vPvb (candidate list) r50, r51, r52 aquatic toxicity substances not
h400 classified as dangerous for the
environment
Note: If information is missing to judge on this criterion, the colour white should be assigned. This indicates that information should be
gathered.
Applicability of criterion
2.1.5. Mobility
Substances used in applications requiring a high mo-
Substances which are very mobile in air and water have
bility (e.g. solvents in printing inks, which have to dry
the potential to disperse in the working and natural
quickly to ensure smooth printing processes) can be
environment as well as in the consumer environment.
evaluated with the criterion only to a limited extent.
Therefore, mobile substances indicate a high likelihood
The relevance of the criterion is to always be decided
of exposures of different subjects of protection. How-
on in relation to the use of a substance.
ever, a high mobility is only critical if substances also
have a high human or environmental toxicity. Further-
Information basis
more, high mobility may lead to high substance losses
Information on the mobility of a substance can be
(resource efficiency).
found in the safety data sheet in section 9 (partly also
sections 2 and 11). Furthermore, public data bases can
A substance’s mobility is determined by its properties
be consulted.
and its use (c.f. Chapter 2.2.1). In this chapter, only subs-
tance properties influencing partitioning and distributi-
Evaluation
on in air and water, as well as the potential to penetrate
In table 6 mobility is assigned to categories (red, yellow,
the skin are discussed. The latter is relevant because if
green). To evaluate the mobility, all subcriteria should
a substance cannot penetrate the skin, dermal exposure
be checked and then summarized in the overall evalu-
is less problematic.
ation (note: not all criteria are applicable to all substan-
ces). The sub-criterion with the most severe evaluation
Relevance:
represents the overall evaluation.
> For society: Emissions at workplaces and in the consu-
mer environment
Note: A high mobility is relevant only if the substance
> For the environment: Emissions of pollutants
is dangerous for man or the environment or if it causes
> For the economy: Losses of substances during use
high losses of the substance. The latter would lead to a
decrease in resource efficiency.

Note: If information is missing to judge on this criterion, the colour white should be assigned. This indicates that information should be gathered.
Table 6: Use aNd evalUaTiON Of The criTeriON “mObiliTy”
evaluation Red YelloW GReen
sub-criterion: Release potential high solubility medium solubility low solubility

in water
indicator solubility in water > 10 mg/l 10 – 0,001 mg/l < 1 µg /l
sub-criterion: Release potential high vapour pressure medium vapour pressure low vapour pressure
to air
indicator Vapour pressure 10-3 to 100 Pa (environment) 10-3 - 10 –8 Pa (environment) < 10 –8 Pa (environment)
> 25 Pa (humans) 0.5 – 25 Pa (humans) < 0.5 Pa (humans)
sub-criterion: long-range substance is transported over indications on persistence and no long-range transport
transport long distances transport
indicator: substance is persistent (half- indications or suspicion of there is evidence that the sub-
Persistence, indications on life in air > 2 days), vapour longrange transport stance is not transported over
long-range transport pressure < 1 hPa or substance is long distances, not persistent
found in pristine environments.
sub-criterion Release potential Very dusty dusty not dusty

at workplaces
indicator dosage form of aerosols & gases, substance substance which are pulverised liquids, non-dusty solid sub-
manufacturer which form clouds of dusts, but not too dusty, dust deposits stances
which remain in the air for a quickly. (Pellets, waxes, granulates...)
longer time
sub-criterion General release use in mixtures, or intended is released unintentionally from Firm embedding in matrix or
potential release form articles articles containment inside articles
the following sub-criteria are not relevant for manufacturers of substances
indicator: use in mixtures. substance substance is not used in embedding of substance in

Release (migration), integration is contained in articles, from mixtures and it is not known matrix or containment in inside
in product matrices which it is intended to be that it is released from the product, no use in mixtures
released matrix during the lifecycle of
the product.
Overall evaluation
Note: a high mobility is relevant only if the substance is dangerous for man or the environment or if it causes high losses of the subs-
tance. the latter would lead to a decrease in resource efficiency.
2.1.6. Origin of raw materials world. However, big differences may also exist between
This criterion addresses the environmental and social enterprises located in the same region.
responsibility taken by the suppliers. If the quality of
raw materials is the same, normally the price is decisive Relevance
for the choice of suppliers. If raw materials are selec- > For the environment: Damage at the location of raw
ted according to their sustainability, the conditions of materials production
environmental protection and workplace health and > For society: Conditions at workplaces and social stan-
safety should be considered for their manufacture and dards
in the purchasing decision. The standards on environ- > For the economy: Costs of raw materials, support for
mental and workers protection (safety and health at the enterprises and regions which produce sustainably
workplace, fair pay etc.) can be very different across the

Applicability of criterion the quality of chemicals supplied can be used as criteria,
2.0 Taking responsibility for the environment and social as well as the existence of “Codes of Conduct”, requiring
conditions should be evaluated, first for suppliers from compliance with social standards. The engagement in
which high amounts of raw materials are obtained. social projects (social sponsoring, specific projects for the
Suppliers, for which little information is available, could environment or on sustainability, research) may also be
also be evaluated. assessed. In principle, information reviewed by indepen-
dent auditors should be weighted higher than that which
Information basis is “purely voluntary”.
To evaluate whether or not suppliers feel responsible for
environmental protection and agreeable social condi- Evaluation
tions not only within, but also in the nearer context of In table 7 origins of raw materials are assigned to cate-
their companies, information on the suppliers themselves gories (red, yellow, green). The higher the commitment
is to be obtained. Information sources could be state- to comply with protection standards at workplaces and
ments on corporate policies or sustainability and environ- for the environment, the more responsible and hence
mental reports in the context of certified management sustainable a supplier is. The borderline cannot be “ob-
systems (workers protection: BA 18000; quality: ISO 9000; jective” but if several suppliers are evaluated they could
environment: ISO 14000 or EMAS). Furthermore, the wil- be ranked or assigned to relative categories of sustain-
lingness to provide information, the overall service and ability.
table 7: uSe and evaluation of the criterion “oriGin of raW MaterialS”
Note: If information is missing to judge on this criterion, the colour white should be assigned. This indicates that information
sub-criterion: the supplier doesn’t care about supplier complies with legal supplier values workers protec-
responsibility for workplaces workers protection. requirements on workers pro- tion very high
tection
indicator no management system is Quality control and workers Good (documented) manage-
management system, risk mentioned in the company protection measures are ment system (e.g. ba 18.000),
management at work policy, workers protection is implemented, no independent implementation of standards,
not an issue auditing voluntary measures (indepen-
dent audits, certification)
umweltschutz ist nachweislich
wichtig für den lieferanten.
sub-criterion: supplier doesn’t care about there are indications that environmental protection is
responsibility for the environ- environmental protection environmental legislation is very important to the supplier
ment complied with.
indicator no management systems and environmental management Good (documented) manage-

management system, emission environmental protection goals system (emas, iso 14,000) ment system (emas, iso 14,000
reduction etc. in the company policy exists; standards implemented, product labels etc.), standards
no independent auditing implemented, independent
audit / certification
sub-criterion: no involvement in social activi- there are indications that improvement of social
social responsibility ties in and outside company social standards are important conditions is important to the
to the supplier. supplier
indicator no information on social activi- supplier is involved in social supplier has “code of
should be gathered.
social activities and goals ties, no training and education projects outside the company conduct”, is social sponsor
in company and provides training in the
company.
total evaluation

2.1.7. emission of greenhouse gases due to manufacture of a substance. The amount of CO2-equivalents identi-
of raw materials or of the substance itself fied as being emitted for the production of 1 kg of a
The effects of a substance on the global climate can be substances is to be multiplied with the amount needed
measured by the emission of greenhouse gases caused to perform the function, in order to compare alterna-
for its production26. This regards emissions in the tives. This approachs allows to compare alternative
upstream chain – for obtaining raw materials - and the solutions which differ in the amount of substances they
substance manufacture itself. The basis for evaluation is need.
the calculated amount of CO2-equivalents. This amount
is normally dominated by the energy consumption If substances manufactured from the same or similar
and transports for obtaining raw materials. Therefore, raw materials are compared, the criterion greenhouse
the criterion is frequently correlated with the resource potential is frequently not selective enough due to lack
consumption (c.f. Chapter 2.1.8). of specific data for specific substances.
Relevance Information basis

> For the environment: Anthropogenic greenhouse effect Information on the greenhouse gas emissions caused
> For society: Climate change and its consequences by the manufacture of a substance can be found, for
> For the economy: Costs of climate change example in the data base Probas of the German Envi-
ronment Agency (c.f. Annex 3). If the substance under
Applicability of criterion evaluation is not contained in the data base, it may be
The absolute values of CO2-equivalents emitted along possible to select a substance which is produced in a
the lifecycle of a substance normally have a low expres- similar manner (similar raw materials, similar proces-
siveness. The evaluation is more meaningful, if done in sing techniques). The compilation of a greenhouse gas
a comparative manner. The amounts of the substance balance for a substance is highly acknowledgeable, but
needed in order to fulfil a certain function should be very time and resource consuming.
used as point of reference, rather than a total amount
E
meanwhile, producers of some products (e.g. construction materials) develop environmental
product declarations (ePd). these consist of a product-specific greenhouse gas balance, among
others. such environmental product declarations would enable users of chemicals to reliably
compare greenhouse gas emissions. in 2009, the international chemicals association (icca)
published eco balances of selected chemicals (icca 2009)27.

Evaluation 2.1.8. resource consumption for the manufacture of raw
2.0 The criterion greenhouse potential is measured in CO2- materials and the substance
equivalents emitted for the production of a substance. For the manufacture of substances28 raw materials,
As first step, it should be assessed what amount (in kilo- water and energy are consumed29. The high resource
gram) of a substance is necessary for a respective use. consumptions for the manufacture of substances can
Only then can a comparative assessment be performed. be an indication of low sustainability. This is true, for
example if comparable alternatives are available, for
The approach to evaluate greenhouse gas emissions which less resources are consumed.
proposed in this guide assumes the following:
The evaluation of the resource consumption for the
On average, 5 kg CO2-equivalents are released if 1 kg manufacture of a substance requires considering the
of an anorganic or organic substance is produced. For upstream chains of a raw material or substance. This is
a first estimation the following advice can be given: in particular:
releases of greenhouse gases will be less relevant for a > obtaining raw materials (e.g. extraction and transport
substance if they amount to approximately 1/5 of this of mineral oil, excavation and transport of minerals
value. Therefore a value of 1 kg CO2-equivalents/ kg or metal ores, cultivation of renewable resources),
substance is given in the following table. However, if > refining of raw materials (purification) as well as
very high amounts of a substance are used, even low > chemical synthesis
greenhouse gas emissions per kilogram may result in a The type of raw materials reflects another aspect of
high total amount. Here, possibilities should be checked sustainability (fossil raw materials, renewable, etc.). Fur-
to reduce emissions of greenhouse gases - including the thermore, the amount of waste produced per amount
assessment of the benefits of a use (c.f. Chapter 2.2.6). of manufactured substance (including waste from
upstream chains) is an indicator of resource efficiency.
The values provided in table 8 are first indicators for
the evaluation, referring to information from the life Relevance
cycle assessment data base PROBAS (see annex 3). For > For the environment: Consumption of resources
more comprehensive statements, a comparative case-by- > For society: Use of resources of future generations
case assessment is necessary, which does not relate to a > For the economy: Cost reduction if resource efficiency
fixed amount of the substance (1 kg), but to the amount is increased
necessary to fulfil the desired function.
The identification of specific data on resource consump-
tions (including upstream chains) requires a compre-
hensive analysis of processing steps and uses of mate-
rials, which is normally too extensive to perform in
addition to every day company work. Therefore, in this
guide a simplified approach and set of criteria is propo-
sed that is sufficient for a first, qualitative evaluation.
table 8: uSe and evaluation of the criterion “GreenhouSe GaS potential”
criterion: high emissions of greenhouse medium emissions of green- low emissions of greenhouse
Greenhouse potential gases house gases gases
indicator aggregated green- > 50 1 – 50 <1

house gas emissions as co2-
equivalents / kg substance
in any case a comparative case-by-case assessment considering the functional unit is necessary.
Note: If information is missing to judge on this criterion, the colour white should be assigned. This indicates that information should be
gathered.

Applicability of the criterion Evaluation – first categorisation
The absolute values of the consumption of energy, The following table outlines rough categories related to
raw materials and water, as well as the quotient of the the manufacture of substances and the consumed re-
amounts of waste per manufactured product are nor- sources: metals, minerals, bulk materials from minerals,
mally not very expressive. Only the comparison of two substances made from mineral oil, substances made
alternatives results in selective judgements regarding from biological materials and wastes.
the resource efficiency of a substance.
The following table provides as a rough indication some

benchmarks to distinguish “high”, “medium” and “low”
relevance of the criterion. The figures are based on
information from the data base PROBAS. If a substance
is used in high amounts, the criterion should be taken
into account anyway.
Excursus:
also renewable resources
can be non-sustainable if
their cultivation is connected
to high resource consump-
tions, e.g. in form of ferti-
lisers and pesticides. their
cultivation could compete
with other land uses, e.g.
the production of food or require high water consumptions
(e.g. cotton). Packaging made of corn starch is an example
of a product that has been negatively assessed in lifecycle
analyses (high energy and material consumption).
chapter 4.1 of the background paper of the German environ-

ment agency on sustainable chemistry30. describes more
in detail sustainability aspects of renewable raw materials.
in Germany two sustainability regulations exists referring
to different kinds of bio fuels. they contain specific criteria
for sustainability, e.g. protection of areas with high value
for nature protection, protection of peat bog, sustainable
agricultural use and greenhouse gas emission reduction
potential (bGb 2009).
substances for which low resource consumption has been

identified can be used inefficiently and therefore also non-
sustainably. according to the Rio-declaration31, renewable
resources should be consumed only to the extent they rege-
nerate. a translation of this principle into company practice
means to check if the global consumption of a specific raw
material exceeds the regenerated amount. indicators for
excessive use can be declines of respective “populations” or
stocks, increased prices due to scarcity or literature review-
ing the use and cultivation of renewable resources.
Even renewable resources such as cotton and packaging
made from maize meal starch can have a bad LCA.

2.0 Table 9: Use and evalUaTion of The criTerion “Use of resoUrces”
evaluation Red YelloW GReen
sub-criterion: non-renewable and scarce raw non-renewable raw materials Renewable raw materials used
Renewability of resources materials available in large amounts. below the amount that is rege-
Renewable resources used in nerated, wastes
excess or produced with high
resource consumption
indicator e.g. fossil raw materials the non-scarce fossil raw materials sustainably used raw materials,
type of raw material - prelimi- stocks of which are limited. (some minerals and gases) recovered substances from
nary evaluation Raw materials which are diffi- which can be obtained with wastes e.g. gelatine
cult to reach (e.g. underground comparably low efforts (surface
mining, deep drilling, high mining, low refinement efforts)
efforts for purification, etc.), e.g. iron
Note: If information is missing to judge on this criterion, the colour white should be assigned. This indicates that information should be gathered.
e.g. beryllium
Renewable raw materials (origin: plants or animals) can be yellow

or green
a case-by-case assessment is necessary
sub-criterion: high energy consumption medium energy consumption low energy consumption
energy consumption
indicator some metals, some minerals some mineral bulk materials, some substances of biological
type of raw material – prelimi- substances from mineral oil and origin, substances recovered
nary evaluation natural gas from wastes
Renewable raw materials (origin: plants or animals) can be yellow

or green
sub-criterion: high water consumption medium water consumption low water consumption
Water consumption
indicator some metals, some minerals some mineral substances, some substances of biological
type of raw material – prelimi- substances from wastes origin, substances made of
nary evaluation mineral oil

note: the criterion might be less relevant if water consumption is below 5 l/ kg substance. it might be
highly relevant if water consumption is above 100 l/kg substance.
sub-criterion: high quotient of waste per medium quotient of waste per low quotient of waste per
amount of waste product product product
indicator some metals, some minerals some mineral bulk substances, some substances of biological
type of raw material – prelimi- substances from mineral oil and origin, substances from wastes
nary evaluation natural gas

note: the criterion might be less relevant if amount of waste is below 1 kg/ kg substance. it might be
highly relevant if amount of waste is above 50 kg/kg substance.
Total evaluation

Remark: The waste phase and the possibility to recycle 2.1.9. summary of evaluation
materials from waste streams are of high importance This guidance does not intend to lead to a one-number
for the sustainability of a substance. See chapter 2.2.4 sustainability assessment. It is possible to sum up the
for details. results of the single criteria in a number. However this
could lead to a loss of information – instead of using
Evaluation – Indications for a more detailed the results of the single criteria.
assessment
The above listed criteria can also be used to compare Therefore we do not propose a final evaluation for a
substances in detail, (type of raw material, consumption substance with one colour covering all criteria (see also
of energy and water, amount of waste). Respective data chapter 1.6 of this guidance). The results of the single
have been compiled in the context of lifecycle analyses criteria should be used for improvements regarding
(LCA) and other methods for the assessment of materials different aspects of sustainability – for one substance
and processes. However, they are of course not available and his life cycle or for a comparison between two or
for all substances. more substances.
In Annex 3, data bases are listed which may be helpful In table 10, the substance-specific criteria are summa-
for a detailed evaluation. If two substances are com- rised. This table should be filled in separately for each
pared it is important that the same methods and data substance that is evaluated. If a mixture is evaluated,
bases are used for both substances. the results for the mixture could be filled in or, if only
components of the mixture are evaluated, one table
The differences within the above categories can be for each component should be filled. The result is a
identified more clearly in a detailed evaluation. Since sustainability profile of the substance or the mixture,
such evaluations can be very time consuming, they respectively.
should only be started if it has been determined that
the resource consumption is decisive for the evaluation
of the sustainability of a substance.
Excursus:
as already mentioned in the previous chapter, for some products of different sectors, envi-
ronmental product declarations (ePd) are available. the product related analysis includes
an inventory of environmental indicators, among other the consumption of energy and the
generation of wastes. such environmental product declarations could enable users of sub-
stances and mixtures to make a comparative assessment based on sound data on resource
consumption for the manufacture of substances.
TablE 10: susTainabiliTy profilE for a subsTancE
substance-specific criteria Red White YelloW GReen
mentioning on substance lists
Physico-chemical properties
human toxicity
dangerousness for the environment
mobility
origin of substance: environmental and social standards
Greenhouse potential including upstream chains
Resource consumption including upstream chains

2.2. usE-spEcific criTEria for ThE EvaluaTion of In the following chapters these seven criteria are descri-
2.0 susTainabiliTy bed. Main points are the meaning of the criteria, the
The use-specific criteria for the evaluation of the sus- applicability, the information basis, the relevance rela-
tainability of a substance or mixture should be used to ted to the substance-specific criteria and the evaluation.
better value or weight the results of the evaluation of
substance-specific criteria. The use-specific criteria are 2.2.1. Emission potential of the use of a substance or
described in more a qualitative way, compared to the mixture32
substance-specific criteria, because due to the high vari- In this guide, the “emission potential of a use” is under-
ety of uses of substances and mixtures, no structure can stood as an estimation of the amounts of a substance
be defined that includes the majority of cases and no (as such or contained in mixtures or articles) which are
generally applicable and unambiguous indicators can released along its lifecycle. The releases could occur
be defined. This chapter therefore supports the reflec- from industrial installations to the environment, to the
tion of the results of the first evaluation steps. workplaces or from products into the living environ-
ment. These releases normally result in a contact with
The results of the application of the substance-specific man or the environment (exposure) and potentially may
criteria should be used in the following way: cause damage.
> A need for action due to substances on lists, dan-
gerous physico-chemical properties and origin of raw Substances are not sustainable if they exhibit problema-
materials (criteria 1,2 and 6) is independent from the tic substance properties and if they are released during
use-specific criteria; their use, which may finally cause adverse effects in
> For substances with dangerous properties regarding man and the environment. If substances are of very
man and the environment (criteria 3 and4) the use- high concern, low releases can already be critical.
specific criteria should be checked in any case;
> For the substance-specific criteria “Greenhouse gas Furthermore, a high emission potential is equal to high
emissions” and “Use of ressources” (criteria 7 and 8) losses of the substance indicating an inefficient use of
especially the use-specific criteria “Emission poten- resources. Therefore this criterion is relevant in relation
tial” and “Use amount” are important; to the resource consumption as well.
> The use-specific criteria “substitution potential”, “be-
nefits potential” and “innovation potential” can mo- The criterion “emission potential of use” is to be related
dify (enhance / decrease) the weight of the substance- to the criteria “user groups” (Chapter 2.2.2) and “mo-
specific criteria “Substance on list”, “Dangerous bility” (Chapter 2.1.5) because the emission potential
physico-chemical properties”, “Human Toxicity”, depends among others on how mobile a substance is
“Problematic properties regarding the environment”, and whether or not it is used in a correct manner.
“Mobility”, “Use of resources” and “Greenhouse poten-
tial” The explanation and support of a comprehensive assess-
ment of emissions along the lifecycle of a substance is
For substance manufacturers, formulators and users not possible in this guide. Publications on this topic can
of substances and mixtures, which have come to the be found on the web in much detail, for example:
conclusion to substitute a chemical because of its sus- > The VCI REACH Practical Guide on Exposure As-
tainability profile, this chapter can still be helpful in sessment and Communication in the Supply Chains
focusing the search for alternatives. introduces to the topics exposure assessment and
communication in the supply chain with several re-
To evaluate the sustainability of chemicals, in this commendations on the implementation in practice33.
second step, seven criteria are proposed that relate to > The guidance document of the European Chemicals
the use: Agency (ECHA) on information requirements and
chemical safety assessment describes a method for
assessing exposures and characterizing risks from the
use of chemicals34
1. the emission potential
2. the user groups The emission potential should be estimated for the
3. the used amounts entire lifecycle of a substance, which means that also
4. the waste stage emissions at the customers, which use the products are
5. the substitution alternatives to be considered.
6. the benefits of a chemical / its use
7. the innovation potential of a chemical / its use

“Mobility” (chapter 2.1.5), because the emission of a sub-
stance depends on its mobility and the way of handling
Substance manufacturers, which have to
the substance.
assess the safety of a substance in the frame
of a REACH registration, should use that in-
Applicability of the criterion
formation in the evaluation of sustainability.
The criterion can be applied to any type of substance
Important information for the evaluation of
(as such or as component of a mixture or article). The
sustainability is e.g. if a high degree of risk
criterion is not very expressive for substances which
management is necessary to ensure safe
are only used as intermediates, as their lifecycle is very
handling and use of a chemical or if certain
short and normally strictly controlled. The lifecycle of
uses are not safe.
substances used as processing aids normally ends with
their actual use inside a mixture (they are not included
in any articles), but includes the waste phase of product
Emissions at the workplace35 could result from evapo- residues.
ration, dusting or skin contact of the chemical and the
worker. The degree of release depends on the type of Information basis
processing and the conditions of use. Emissions into the Information on the use of a substance as such or in
living environment of consumers may result from the mixtures and articles are either available (purpose of
use of chemical mixtures (e.g. air fresheners, paints) product) or have to be requested from the users (com-
through the formation of aerosols, evaporation or munication with customers).
dusting or e.g. through the use in water (dish washing
agent). Furthermore, articles may release substances Evaluation
(e.g. plasticisers in PVC-flooring). In tables 11, 12 and 13, examples of uses with very
high and very low emission potentials are given. In
The environmental emission potential equals to the the first table this is related to the substance-specific
sum of all emissions of the substance from mixtures criteria “dangerous for the environment” and “resource
and articles, which are released to the environment via consumption”. In the second table it is related to the
the air, water or soil. “dangerousness for the worker” and in the third to the
“dangerousness for the consumer”, the latter two being
Relevance related to the substance-specific criteria a more differentiated view on the “human toxicity”.
A high emission equals a high loss of substance. This
is an ineffective use of resources. Therefore the crite- The high emission potentials can enhance the impor-
rion “Emission potential” is relevant for the criterion tance of the evaluation of the substance-specific criteria
“Resource consumption” (chapter 2.1.8). The criterion (dangerous for man and the environment, resource con-
“Emission potential” has to be seen together with the sumption, i.e. yellow > red) and low emission potentials
criterion “User groups” (chapter 2.2.2) and the criterion can attenuate them (red > yellow).

2.0 Table 11: IndIcaTors for The evaluaTIon of The emIssIon poTenTIal of uses relaTed To The envIronmenT36
inFluencinG Factors critical uses, less critical uses,

hiGh emission Potential loW emission Potential
use of the substance as such or in mixtures open use in the environment, in private chemical synthesis; use in large installa-
households in crafts, use in smes+ tions, automated processes
relevance of use regarding water emissions use in aqueous systems or in direct contact substance or mixture does not come into
with environmental media contact with water
“containment” of installation open or semi-open installation, wastewater substance or mixture is used in closed
and exhaust gas are generated systems or installations37.
other conditions of use of substance or Processing at high temperatures and high Processing at room temperature or less, no
mixture pressures, mechanical stress (abrasion, extreme conditions
formation of dusts)
disposal of production wastes or wastes no specific disposal, consumers products disposal by destruction or systematic colle-
from consumer mixtures disposed with wastewater or household ction and recovery / recycling
waste
state-of-the-art of end-of-pipe technologies capture of emissions according to state- exhaust gas and wastewater are cleaned
of-the-art not ensured, all chemicals for and disposed of according to legal require-
consumers ments
substance as part of articles Flat products, coatings, outdoor use, compacted products, indoor use, no
abrasion abrasion
disposal of articles containing the substance Wide dispersive use, no special collection or small group of users, specific waste regimes
disposal system, normally part of household exist (e.g. electric devices, cars etc.)
waste
Influence of mobility (water and air to be mobile substances or substances which substances with low mobility, substances
viewed upon separately) don’t react with article matrices which are firmly embedded in article
matrices
Table 12: IndIcaTors for The evaluaTIon of The emIssIon poTenTIal of uses relaTed To The workplace
inFluencinG Factors critical uses, less critical uses,
use of the substance as such or in mixtures use in installations with low technical stan- installations for chemical synthesis,
dards, professional use in crafts installations with high technical standards
(automated processes)
type of use – dosage of substances and manual dosage of powders and liquids, simple dosage (closed pipes, ready-to-use
mixtures direct feeding of dusty or volatile chemicals packaging), immobilization, e.g. by com-
pounding
type of use - processing high energy or fast processes, low degree automated processes, low energy or slow
of automation. open, manual use (e.g. processing. organisational or technical
spraying, cutting, immersion) separation of worker and chemical
disposal and cleaning no separation of wastes; disposal is not separate disposal through specified waste
regulated, cleaning and maintenance is management company, cleaning and mainte-
conducted untrained personnel nance by expert companies (incl. abatement
equipment)
state-of-the-art o workers protection no management system for workers health, existing management system for workers
few emission reduction measures, use by health, regular risk assessment at work-
professional users, us at “mobile” workplaces and emission reduction measures
places implemented.
influence of mobility (volatility more important mobile substances low mobility of substances
than solubility, log Kow for dermal contact)

TablE 13: indicaTors for ThE EvaluaTion of ThE Emission poTEnTial of usEs rElaTEd To consumErs
inFluencinG FactoRs cRitical uses, less cRitical uses,

type of use of substance or mixture manual dosage of powders and liquids Ready-to-use packaging, tabs, high viscous
mixtures
type of use application spray applications “open uses”, e.g. wiping, use inside machines (e.g. washing), use in
direct contact with skin and lungs specific equipments (e.g. silicone cartridge
guns), direct contact is low
Waste disposal complicated disposal (e.g. paints), cleaning disposal without refilling or cleaning, no
of equipment necessary waste is generated
substance as part of articles substance is not firmly embedded in article substance is integrated in article matrix or
matrix, ca e.g. leach or evaporate during inside closed sub-parts
use
influence of mobility (water and air to be mobile substances or substances which are substances with low mobility or which are
viewed upon separately) not firmly embedded in an article matrix firmly integrated in article matrices
Recommendation: Enterprises should create an overview which processes are characterised by specifi-
cally high substances’ releases. For these processes emission reduction potentials at workplaces or to the
environment as well as improvements of product qualities (healthier products for consumers) and cost
savings are very likely to be high. Hints on how to compile such an overview can be found in the REACH
Practical Guide on Exposure Assessment and Communication in the Supply Chains38.
2.2.2. user groups of a substance Evaluation

Substances are used as such, in mixtures and as part of Vulnerable groups, such as children and pregnant
articles by different groups of persons and in diffe- women, should not come into contact with chemicals
rent environments. For the evaluation it is important which are toxic to human health at all. Workers are of-
whether particularly vulnerable user groups handle the ten exposed to high amounts of substances and at high-
substance, such as children or handicapped people. In er frequencies. Consumers could be exposed to emissi-
principle these groups, which require a higher degree ons of substances form products inside their homes.
of protection, should not be exposed to chemicals,
which may cause harm to human health. In this case, In table 14, for each criterion it is assumed that a “yel-
not only the use of the substance in whatever form is low” evaluation has been concluded for the mobility of
relevant, but also if it is released39 (c.f. Chapter 2.1.5 the substance in the first steps. Using the examples, it
“mobility” and Chapter 2.2.1 “emission potential”). can be derived if the substance-specific characteristics
are enforced or attenuated by the types of user groups.
Relevance related to substance-specific criteria
In relation to the user groups, only the criterion “hu-
man toxicity” is considered, although other criteria
could also be relevant. If vulnerable user groups are
identified, the evaluation results of the criterion human
toxicity should be modified (yellow à red and even
higher urgency for white).
Information basis
The uses of a substance need to be known as well as the
user groups (consumers, vulnerable groups, workers) of
the end product.

2.0 TablE 14: usE and EvaluaTion of ThE criTErion “usEr groups”
substance-sPeciFic cRiteRia enFoRcement attenuation
substance is on lists of problematic sub- use should be avoided for any user group
stances
substance is dangerous to human health substance is used in products for children substance as such and in mixtures is only
or for vulnerable groups. substance is used foreseen for use by professional users.
indoors. substance is used only in consumer arti-
cles, which don’t give rise to releases to
indoor environments
substance is volatile and dissolves well in substance is used in consumer products substance is only used in products for
water and for indoor use. substance is used in professional users
articles from which they are intentionally
released (e.g. pens, fragrance candles)
2.2.3.The use amount Applicability of the criterion

There are no harmonized definitions of which amounts The criterion can be applied to any substance or
are a “high” or “low” amount. Under REACH, registra- mixture. Manufacturers should relate to the substance
tion requirements distinguish between amounts of 1 amount they produce. Formulators could either assess
to 10, 10 to 100, 100 to 1000 and above 1000 t/a. The amounts of a substance used in a mixture or the
amounts should be considered in relation to the dan- amount of the mixture as such. Users of mixtures can
gerous properties: for a substance of very high concern identify the use amount of a component by multiplying
(SVHC) an amount of 1 t/a may already be very high. the concentration in the mixture with the total amount
of the mixture used40.
For articles containing SVHC the concentration limit of
0.1% (weight/weight) set in REACH Art. 7.2 is a reaso- Information basis
nable order of magnitude. In Europe, a concentration The own manufactured or used amount (company infor-
above this limit triggers the legal requirement to make mation) or market volumes of the substance in the EU
a notification to ECHA as described in REACH Art. 7.2. can be used.
In order to avoid non-sustainable impacts on man and Evaluation

the environment, in case of complex articles this con- The use amount as isolated indicator is fairly meaning-
centration limit should refer to the homogeneous mate- less. Therefore, in table 15 the substance-specific crite-
rials within the article. Especially the substance-specific ria are used as basis for the assessment of use amounts.
criteria “Human toxicity” (chapter 2.1.3), “Problematic The high amounts enhance a negative evaluation of the
properties related to the environment” (chapter 2.1.4), substance-specific criteria and low amounts attenuate
“Mobility” (chapter 2.1.5), “Emission of greenhouse ga- them.
ses” (chapter 2.1.7) and “Resource consumption” have to
be seen in connection with the amount used.
Relevance related to substance-specific criteria

High use amounts can enhance the importance of some
Recommendation: Enterprises should in a
substance-specific criteria. The higher the resource
first assessment use their substance inventory
consumption or the emission of greenhouse gases for
in order to get an overview of which of the
the production of a substance, the higher the weight of
critical substances are used in particularly
these criteria in the overall evaluation is. In particular
high amounts.
if large amounts of the substance are produced or used.
Vice versa, if a substance is used in small amounts, the
importance of the criteria “resource consumption” and
“greenhouse gas emissions” should be decreased.

Table 15: Use and evalUaTion of The criTerion “Use amoUnTs”
2.2.4. Waste stage

Some substances may cause risks for man or the en- The evaluation of the waste phase can enhance the re-
vironment when they become waste. Generally, the sults of the criteria “Human toxicity” (chapter 2.1.3) and
recovery of substances from wastes should be aspired “Problematic properties related to the environment”
to save resources and energy. However, recycling could (chapter 2.1.4), “mobility” (chapter 2.1.5) and “Resource
be problematic if substances contaminate a material consumption” (chapter 2.1.8), if indications of problems
stream and reach new products. during the waste phase exist.
Sustainable substances should either fully degrade or Applicability of the criterion

mineralise during disposal (no waste in the long run) For substances which don’t occur in wastes, e.g. because
or be designed in a way that they can be fully recycled they are almost fully emitted during their lifecycle (e.g.
without loss in quality41. Although some indicators of solvents) or because they react with other substances
potential problems during the waste phase exist, it (intermediates, reactive additives) the criterion is not
should be assessed case-by-case whether or not they are applicable.
relevant and if they change the overall evaluation a
substance’s sustainability. Information basis
The final product, in which the substance is used, is In order to assess the waste phase, the substance ma-
of high significance in this assessment, as it normally nufacturer or user has to identify the likely disposal
determines the disposal pathways. pathways of the products (mixtures or articles in indus-
trial, professional and consumer uses) the substance is
Relevance related to substance-specific criteria used in and assess potential problems in relation to the
If a substance or a product containing a substance substance properties.
becomes waste (because the substance is not completely
degradable or is not recycled), the substance-specific Evaluation
criteria get more importance. The following list presents combinations of waste

treatment technologies and substance properties, which > Nanoscale substances can disaggregate/de-agglomerate
2.0 may cause risks to man and the environment. In the and be separated from the product. The behaviour
evaluation of sustainability related to the waste stage of and dangerous properties of nanomaterials in waste
a substance they have to be seen as less sustainable 42: treatment installations, including physico-chemical
> Metal containing compounds can be destroyed in risks are largely unknown. In particular for nanoma-
waste incineration installations and distributed wi- terials the precautionary principle should be applied:
dely in the environment (if no abatement techniques risks, which cannot be assessed, should be prevented
are applied). in the first case.
> PBTs/vPvBs can be released to the environment in dif- > It can be assumed that wastes from industrial instal-
ferent disposal processes, e.g. evaporation or leaching lations are properly disposed of. This is not the case
in landfills. for wastes from professional users or consumers.
> Through thermal and biological processes in landfills, For example, electric and electronic equipment is
dangerous degradation products could be formed and still disposed of as household waste instead of being
reach the environment. separately collected and treated. Therefore a lower
> Problematic substances could contaminate material content of hazardous substances is more important
streams in recycling processes and be contained in for products for professional and private uses.
products manufactured from recovered materials.
The above examples show that additional adverse
> If substances are not recovered as such or as part of impacts may occur during the waste stage. Therefore,
materials (e.g. plastics, metals), they are “lost” (ineffi- the waste stage is of high relevance in the assessment of
cient use of resources). sustainability. If one or more of the above listed items
> Halogenated compounds can lead to the formation of applies to the substance, this is to be evaluated as not
dioxins and furans in thermal processes. These reac- sustainable.
tions can be enhanced by some metals, e.g. copper,
which function as catalysts. 2.2.5. substitution potential
> Substances with high water solubilities could reach The substitution potential of a substance is a criterion
surface waters in different processes of waste collec- applying rather to the alternatives of a use of a subs-
tion, separation and treatment. tance, than the substance itself. The substitution poten-
> Workers in waste treatment installations can be tial affects all of the substance-specific criteria.
exposed to dangerous substances in products and
chemical wastes (without knowing thereof), if articles The substitution potential describes the degree
are dismantled (opening of closed containers, e.g. of availability of alternatives to the use of a problema-
batteries, dangerous operating fluids in cars) or shred- tic substance or mixture. If the use could be replaced
ded (dust formation). These situations don’t normally by other substances / mixtures or by other measures,
occur during the use of a substance as such and in e.g. improved product design or change of processing
products. techniques, and if this is economically and technically

feasible, the substitution potential enforces all negative to substitute decrease and are more complex, the more
evaluations of sustainability criteria, because of specific the functionality of a substance or mixture, or
the potential to avoid the use of the substance or mix- the more essential it is for the product or process it is
ture. used in.
If no alternatives are available, the further use of the Information basis

substance or mixture (and if possible, the implementa- Different types of information are necessary to assess
tion of measures to reduce the non-sustainable aspects alternatives (substitution). These are among others:
of the use of the substance) is inevitable and a negative > Company internal sources for the assessment of finan-
evaluation of sustainability may be acceptable. Howe- cial feasibility of substitution,
ver, the availability of alternatives should be checked > Demands and statements of customers regarding the
regularly to take into account the technical progress quality of products and processes
and new information and substitution experience. > Public data bases on alternatives
> Information on substance properties, uses and poten-
Because substitution is a complex process, no details tial exposures and risks
can be provided in the frame of this guide and no con- > Technical experience on substitution
crete substitution scenarios presented. Practical support
can be obtained from corresponding publications, for Evaluation
example the “technical rules for dangerous substances Each enterprise has to decide for each case, whether or
600” (TRGS 600) 43 by the Federal Agency on Occupa- not the sustainability evaluation requires (or justifies)
tional Health and Safety. A good overview is given in a substitution. The “simpler” and “cheaper” a substitu-
the publication of Lißner and Lohse 2006. In Annex 7, tion, the higher the substitution potential is and the
some basic considerations on substitution are discussed more negative evaluations of sustainability are to be
which can be used for a first assessment. In this chapter weighed. The evaluation cannot be standardized and
only the guiding principles for consideration in substi- no indicators can be given.
tution decisions are introduced:
> Substitution should maintain or even improve the 2.2.6. Benefit potential
quality of a product. The benefit potential of a substance or mixture influ-
> Substitution should not lead to an increase or shift of ences, like the substitution potential, the evaluation
risks for man and the environment. of all substance-specific criteria. The benefit potential
Overall the risks should be reduced (for all subjects of consists of the quality of the (end) products, the societal
protection). and environmental benefits from its use and the corpo-
> Substitution can only be successful, if the technical rate benefits.
precondition exists not only in the own company,
but also at the customers’. This requires for example Substances can have very different functions in mix-
considering if technical processes are fine-tuned to a tures and in articles into which they are included. In
specific substance or mixture, which would require a order to determine the benefit potential, the relevan-
change of the technological process if the substance ce of the substance for the quality or functionality of
or mixture were replaced. the end product is to be identified. The functions of
> Substitution is only a sustainable solution, if society substances in end products can be allocated to different
and corporate costs for the use of alternatives remain categories. One possible differentiation is introduced in
under the costs of potential damage. the following and further explained in Annex 8.
Relevance related to substance-specific criteria Benefit potentials of substances are in most cases
The substitution potential has relevance to all subs- realised only in the end product they are used in. The
tance-specific criteria. As said above, if a substance benefits can be distinguished into:
can not be substituted, the substance-specific criteria > Quality of (end) products. The substance contributes
become less important. However in case of a substance significantly to the product quality (e.g. long life
which has to be considered as less sustainable accor- spans, safety, weight).
ding to these criteria, it has to be checked comprehensi- > Function of (end) products. The end product has got
vely whether alternative solutions exist. a high societal benefit which is realized to a high
extent through the use of the substance.
Applicability of the criterion > Environmental benefits of products comprise of e.g.
In principle it can be assessed for any substance or mix- the improvement of product quality or the use of the
ture whether its use can be avoided or not. From this product to improve the environmental quality (envi-
perspective, the criterion can be applied to any subs- ronmental technologies, e.g. photovoltaic).
tance or mixture and any of their uses. The possibilities > Benefits for the company.

Relevance related to the substance-specific criteria velopment. Herewith, the market position of the innova-
2.0 The evaluation of the benefit potential through a speci- ting company may also be improved.
fic functionality of a substance, mixture or end product
can influence the overall result of the evaluation of The chances generated through the use of sustainable
all substance-specific criteria. If benefits are very high, substances (avoiding problems of nonsustainable pro-
negative sustainability profiles may be acceptable or ducts, improving overall product qualities etc.) related
relativised. to product and process innovations and the penetration
of innovative products on the markets used should be
The approach of balancing costs and benefits is pursued considered as a “plus” in the evaluation of sustainability
among other in socio-economic analyses (SEA) 44. A com- of products. The possibility to transparently document
plete SEA is very complex and cumbersome but leads and communicate aspects of sustainability is very im-
to valuable information to evaluate the sustainability portant in this context.
of a substance. By using “common sense”, societal costs
and benefits can be identified at a much rougher level, The sustainability of substances and products plays a
which although being much less differentiated and not role especially in ecologically-sensitive markets (ecolo-
“proven” frequently results in the same conclusions as a gically produced products, like organic foods, clothing
detailed SEA. or furniture). In the future, demands for such products
will be even higher for substances, which are contained
Applicability of the criterion in consumer products with high relevance for human
The criterion is applicable to all substances. health (e.g. clothing, cosmetics, products for infants,
construction products for indoor use). The manufacture
Information basis and use of sustainable substances is also important in
The functionalities of substances are based on their filling respective company policies with life.
properties and are normally known and intended by
substance manufacturers and users. Relevance related to substance-specific criteria
The innovation potential has relevance to all substance-
The functionalities of mixtures are achieved by com- specific criteria. It enhances the importance of positive
bining single substance and their properties are nor- results of the application of these criteria.
mally well known as well. However, sometimes the in-
teraction of substances is important in mixtures, which Applicability of the criterion
may hinder the clear identification of contributions of The connection between the uses of sustainable subs-
the substance which is evaluated. tance with innovation activities is rather a question of
the design of the innovation processes and its timing,
If substances are used in articles, only very superfluous than a question of the evaluation of sustainability of
functions as well as those which have a very high bene- substances. The criterion can be applied to any subs-
fit can be unambiguously attributed to single substan- tance or mixture.
ces. In most cases this is not possible, in particular for
bulk chemicals with different uses. Here, the article as Information basis
such should be submitted to a benefit assessment and The criterion can be applied using internal knowledge
issues of product design become more relevant. of markets, products and production processes..
Evaluation Evaluation
The evaluation of the benefits of the use of chemicals Different actors in society can achieve very different
can, depending on the type of actor, be viewed upon results in assessing the innovation potential of the use
differently. This is particularly true for products which of a specific substance. This is the case especially for
are very profitable for companies but are critical with products which might offer a high economic potential,
regard to their impacts on the environment or socie- however they have to be considered as problematic
ty. The criterion should be used to analyse benefits of regarding their impacts on man and the environment.
a product, but doesn’t suffice to support an indepth
discussion of different stakeholders on the benefits of a In this situation the criterion proposed at least supports
substance. a transparent analysis of the innovation potential of a
substance or a mixture.
2.2.7. Innovation potential
In all economic areas, the sustainability of products
should be aimed at. The criteria for sustainable chemicals
can influence the direction of innovation in a positive
way, if already applied in the early stages of product de-

Sources: 34 The guidance is available at the European Chemicals Agency: http://
6 www.gadsl.org guidance.echa.europa.eu/guidance_en.htm
7 OSPAR: Convention on the protection of the marine environment of the 35 Guidance for a detailed assessment of emissions and exposures of
North-East Atlantic dangerous substances at workplaces can be found in the “Easy-to-use
8 HELCOM: Commission on the protection of the marine environment of workplace control scheme for hazardous substances” (Einfaches Maßnah-
the Baltic Sea menkonzept) of the Federal Agency on Occupational Health and Safety,
9 Note that the authors of this guidance consider this type of product as including help for practical risk management measures.
such as being not sustainable as a low societal benefit is contrasted with 36 Source: Federal Environment Agency: Guidance for the use of environ-
high risks to humans and the environment and high losses of materials mentally sound substances – part 2, Berlin 2003; http://www.umweltbun-
and energy. desamt.de/wasser-e/themen/stoffhaushalt/umweltvertraegliche-stoffe/
10 This may take until 2018 for low volume substances which have been on inventare.htm. The table has been slightly modified.
the market before REACH entered into force. 37 As preliminary guiding value an annual loss of materials of less than
11 http://www.gsbl.de/index.html 0.001 to 1% compared to the input amount tot he system can be used.
12 http://ecb.jrc.ec.europa.eu/classification-labelling/search-classlab/ The target values have to be defined specifically for sectors, substances
13 Here, R-phrases can be directly translated to H-phrases of the CLP- and processes.
regulation. 38 Chapter 5.3.1 of the REACH-guide; http://www.cefic.org/Files/Publica-
14 The H-phrases H224 – H226 apply to liquid substances. Details can be tions/Doc-1-Part-1-to-3-Practical-Guidance-final.pdf (english version)
obtained from the translation tables of the CLP-regulation (Annex VII). and http://www.vci.de/default~cmd~shd~docnr~125022~lastDok
The H-phrases can be used for very flammable and for flammable subs- Nr~102474.htm (german version)
tances. A case-by-case decision should be taken on whether a substance 39 Here, the criteria “mobility” and “emission potential” are not conside-
falls into the category “red” or “yellow”. red. However, it is recommended to view the use amount in conjunction
15 The assignment of R-phrases is oriented towards the “Easy-to-use work- with these criteria, because for example even sensitive or vulnerable
place control scheme for hazardous substances” of the Federal Institute groups users may not be at risk, if the substance has a low mobility and
for Occupational Safety and Health: http://www.baua.de/nn_37642/en/ is used in closed systems.
Topics-from-A-to-Z/Hazardous-Substances/workplace-control-scheme. 40 The concentration in a mixture is only specified in the safety data sheet
pdf? if the substance is classified as dangerous. It may be useful to contact
16 Some substances penetrate the skin, enter the body and could cause the supplier for more information.
adverse effects. The TRGS 900 lists substances for which occupational 41 Due to this, substances have to be stable and easily separable.
exposure limit values have been set in Germany. The column “com- 42 The ECHA guidance document on information requirements and che-
ments” specifies if a substance penetrates the skin. http://www.baua.de/ mical safety assessment (IR/CSA – R18) contains a part on assessing risks
nn_16806/de/Themen-von-A-Z/Gefahrstoffe/TRGS/pdf/TRGS-900.pdf? of substances in their waste stage, including guidance on quantitative
17 The assignment of R-phrases is oriented towards the “Easy-to-use work- assessments. This part of the guidance is currently under revision.
place control scheme for hazardous substances (einfaches Maßnahmen- 43 43 www.baua.bund.de/nn_78960/de/Themen-von-A-Z/Gefahrstoffe/TRGS/
konzept)” of the Federal Institute for Occupational Safety and Health: pdf/TRGS-600.pdf
http://www.baua.de/nn_37642/en/Topics-from-A-to-Z/Hazardous- Subs- 44 The socio-economic analysis aims at a structured compilation of societal
tances/workplace-control-scheme.pdf? benefits and costs of a certain issue. In the past, such analyses have
18 The H-phrase H370 addresses systemic damage according to the GHS. among others been performed in the frame of the “existing substances
It corresponds to several R-phrases and is therefore mentioned in the programme” of the EU in order to identify those measures, which lead
columns “red” and “yellow”. Here, the “old” EU classification system is to the highest risk reduction in the use of a substance and which are
less ambiguous. connected with the lowest costs and highest societal benefits. In a SEA,
19 The H-phrase H314 is used for irritating substances of category 1A and different parameters are quantified and described as costs and savings.
1B, which corresponds to the R-phrases R34 and R35. Under REACH, the socio-economic analysis will be applied by industry
20 Some substances penetrate the skin, enter into the body and may cause in the context of applying for an authorization of a use of a substance. A
adverse effects. The TRGS 900 lists substances for which occupational ex- separate guidance document is intended to be developed.
posure limit values have been set in Germany. The column “comments”
specifies if a substance may penetrate the skin. http://www.baua.de/
nn_16806/de/Themen-von-A-Z/Gefahrstoffe/TRGS/pdf/TRGS-900.pdf?
21 The registration of low volume substances (production or import volume
between 1 and 10 tonnes per year) will be finalized by 2018. However,
for these substances, the required data set to be generated will not
allow a thorough PBT/vPvB assessment, as no BCF or half-life needs to be
determined, but only the LogKow and easy degradability.
22 http://oberon.sourceoecd.org/vl=7718146/cl=11/nw=1/rpsv/cw/vhosts/
oecdjournals/1607310x/v1n3/contp1-1.htm
23 The CLP-regulation has only one category for acute aquatic toxicity. The
H-phrases analogous to the R51 and R52 only exist in combination and
address the chronic toxicity.
24 The criteria are given in the Annex.
25 It is possible that a substance is inherently not degradable and has a
LogKow of more than 4. These are indications that the substance may be
a PBT/vPvB. Further data is necessary for a comparison of the respective
criteria (e.g. simulation test on degradability and/or study determining a
BCF).
26 Also gases other than CO 2 are relevant for the climate, e.g. methane and
SF6. All emissions of substances are normalized to the effects of CO 2 and
the greenhouse potential is then measured in CO 2 -equivalents.
27 ICCA International Council of Chemical Association 2009: Innovations
for Greenhouse Gas Reductions. A lifecycle quantification of carbon
abatement solutions enabled by the chemical industry, July 2009; http://
www.icca-chem.org/ICCADocs/ICCA_A4_LR.pdf
28 The resource efficiency of the manufacture of a substance is to be
correlated with the benefits of its use regarding the resource use along
the supply chain, in order to obtain a full picture. However, this requires
indepth knowledge on the uses and application processes of a substance
and is a very complex task, which cannot be elaborated in this guide.
29 In a holistic perspective, additional production factors would be
included, such as the use of machines and auxiliary materials or land
consumption. In order to make the criterion manageable at company
level, only the above mentioned factors are used.
30 http://www.umweltbundesamt.de/uba-info-medien/mysql_medien.php?a
nfrage=Kennummer&Suchwort=3734
31 The Rio Declaration has been stated during the conference of the
United Nations for Environment and Development, taking place in Rio
de Janeiro from June, 3.-14. 1992 (see http://www.quetzal-leipzig.de/
printausgaben/ausgabe-02-umwelt-und-entwicklung-in-lateinamerika/
erklarung-der-unced-19093.html).
32 Further explanation to this criterion is provided in Annex 4.
33 The “REACH guidance on exposure assessment and communication in
the supply chain” including examples can be downloaded at: http://
www.cefic.org/Files/Publications/Doc-1-Part-1-to-3-Practical-Guidance-
final.pdf (english version) and http://www.vci.de/default~cmd~shd~docn
r~125022~lastDokNr~102474.htm (german version).

3.0
Golden ruleS
The following “10 golden rules” summarise the most important
principles of sustainable chemicals. Of course, this is only pos-
sible by making some rather rough simplifications. Therefore,
the following rules do not replace the detailed explanation of
the previous chapters, but highlight the core issues to consider
and facilitate orientating chemicals management towards su-
stainability.
1.
if possible, only use
substances (as such, in
mixtures or in articles)
which are not menti-
oned on lists of proble-
matic substances!
3.
as much as possible use substances which are not
dangerous to human health (in particular none, which
are classified as carcinogen, mutagen or reprotoxic),
which are easily degraded, don’t bioaccumulate and
don’t widely disperse in the environment!
4.
2. Prefer substances which are
assess the different uses and potential users of the available in excess or made
substance as such, in mixtures or in articles in detail from renewable resources to
and take responsibility for the consequences of its substances which are scarce
use. never look at the substance in isolation but think and produced from fossil raw
through the entire lifecycle in the evaluation! materials!

8.
assess whether your suppliers conform to high
environmental and social standards. select substances
considering the transparency of the supply chain and
the commitment of its actors to sustainability!
9.
Your suppliers should elaborate environmental product
5. declarations for substances supplied in large amounts.

in these ePds they should document the resource and
avoid long-distance transports at any stage of the
energy consumption related to the manufacture of
supply chain, in particular for substances which you use
the substance, as well as generated greenhouse gas
in high amounts!
emissions. make ePds yourself, if possible, to document
the sustainability of your products.
6.
Pay attention to a low energy and water consumption of
substances you use in large amounts as well as to a low
generation of wastes in manufacturing and use!
10.
conduct independent studies on the environmental and
health risks of the substances and / or products you
want to place on the market. Provide specific and high
quality data, such as test results.
7.
don’t use substances, which require a high degree of
risk management according to the Furthermore products should not be put on the market
easy-to-use workplace control scheme for hazardous for which a societal benefit and a benefit for consumers
substances or the coshh approach! can not be identified.

O
This guide should support manufacturers, formulators and end

users of substances and mixtures to consider aspects of sustai-
nability in selecting their chemicals.
taBle 16: ComparISon of SuStaInaBIlIty profIleS of formaldehyde and phenol
substance-sPeciFic cRiteRia FoRmaldehyde Phenol
mentioning on substance lists green green
Physico-chemical properties green green
human toxicity red red
dangerousness for the environment green green
mobility red red
origin of substance: environmental and social standards
Greenhouse potential including upstream chains green yellow
Resource consumption including upstream chains red red
The criteria introduced in Chapter 2 enable analysing For both substances, the sustainability profile shows
which aspects of a substance require action or further that measures could improve the sustainability of
information gathering. Table 16 shows the results of these substances. Due to the dangerous properties for
assessing two example substances with the help of the humans and the high mobility of the substances, the
substance-specific criteria. possibilities of substituting with alternatives with less
critical properties should be assessed. If no alternatives
Both substances are critical regarding their human are available, the problematic impacts may be reduced
toxicity, their mobility and their resource consumpti- by the implementation of risk management measures.
on. Most criteria are evaluated with a similar outcome. In order to clarify environmental and social standards
Only the greenhouse potential appears to be higher for in the supply chain, targeted requests are necessary in
phenol. For both substances, no information is available both cases.
on the implementation of environmental and social
standards in the supply chain.

5.0
05. lIterature
Baua: Easy-to-use workplace control scheme for hazar-

dous substances. http://www.baua.de/nn_37642/en/
Topics-from-A-to-Z/Hazardous-Substances/workplace-
control-scheme.pdf?
federal environment agency: Guidance for the use of

environmentally sound substances, part 2, Berlin 2003.
http://www.umweltbundesamt.de/wasser-e/themen/
stoffhaushalt/umweltvertraegliche-stoffe/inventare.htm
ICCa International Council of Chemical association 2009:

Innovations for Greenhouse Gas Reductions. A life cycle
quantification of carbon abatement solutions enabled
by the chemical industry. July 2009; http://www.icca-
chem.org/ICCADocs/ICCA_A4_LR.pdfACC A
lißner, l.; lohse, J. (2006); Braucht Substitution mehr

Staat oder mehr Markt? In: UWSF – Z Umweltchem
Ökotox 18 (3) 193 – 200
reGulatIon (eC) no 1907/2006 of the european

parlIament and of the CounCIl of 18 December 2006
concerning the Registration, Evaluation, Authorisation
and Restriction of Chemicals (REACH), establishing
a European Chemicals Agency, amending Directive
1999/45/EC and repealing Council Regulation (EEC) No
793/93 and Commission Regulation (EC) No 1488/94
as well as Council Directive 76/769/EEC and Commis-
sion Directives 91/155/EEC, 93/67/EEC, 93/105/EC and
2000/21/EC
reGulatIon (eC) no 1272/2008 of the european

parlIament and of the CounCIl of 16 December 2008
on classification, labelling and packaging of substan-
ces and mixtures, amending and repealing Directives
67/548/EEC and 1999/45/EC, and amending Regulation
(EC) No 1907/2006

ABBREVIATIONS
ARTICLE AN OBJECT WITH A SPECIAL SHAPE, SURFACE OR DESIGN WHICH DETERMINES

ITS FUNCTION TO A GREATER DEGREE THAN DOES ITS CHEMICAL COMPOSITION
BAT BEST AVAILABLE TECHNIQUES
BCF BIOCONCENTRATION FACTOR
BREF BEST AVAILABLE TECHNIQUES REFERENCE DOCUMENT
CAS CHEMICAL ABSTRACT SERVICE
C&L CLASSIFICATION AND LABELLING
COSHH CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH. APPROACH FROM GREAT
BRITAIN FOR THE DERIVATION OF RISK MANAGEMENT MEASURES FOR WORK
PLACE
CLP CLASSIFICATION, LABELLING AND PACKAGING
CMR CARCINOGENIC, MUTAGENIC OR REPROTOXIC SUBSTANCE
DNEL DERIVED NO EFFECT LEVEL
DPD+ METHOD TO IDENTIFY LEAD SUBSTANCES IN MIXTURES BASED ON THE DANGEROUS
PREPARATION DIRECTIVE
ECHA EUROPEAN CHEMICALS AGENCY
EDC ENDOCRINE DISRUPTING CHEMICAL
EMKG EINFACHES MAßNAHMENKONZEPT GEFAHRSTOFFE (SIMPLE CONCEPT OF MEASURES
FOR DANGEROUS SUBSTANCES) = EASY-TO-USE WORKPLACE CONTROL SCHEME FOR
HAZARDOUS SUBSTANCES
EPD ENVIRONMENTAL PRODUCT DECLARATION
EXPOSURE EXPONERE (LAT): TO BE SET OUT; CONTACT BETWEEN A CHEMICAL SUBSTANCE OR
A PHYSICAL OR BIOLOGICAL AGENT ON THE ONE HAND AND AN ORGANISM OR AN
ENVIRONMENTAL COMPARTMENT ON THE OTHER.
HACCP HAZARD ANALYSIS AND CRITICAL CONTROL POINT
LCA LIFECYCLE ANALYSIS
LC50 LETHAL CONCENTRATION; CONCENTRATION CAUSING 50% OF TEST ORGANISMS
TO DIE
LOGKOW LOGARITHM OF THE PARTITIONING COEFFICIENT BETWEEN WATER AND OCTANOL
MIXTURE A MIXTURE OR SOLUTION COMPOSED OF TWO OR MORE SUBSTANCES (CLP
REGULATION). THIS TERM REPLACES THE TERM “PREPARATION”.
PBT PERSISTENT, BIOCCUMULATIVE AND TOXIC SUBSTANCE
PC PHYSICO-CHEMICAL
PEC PREDICTED ENVIRONMENTAL CONCENTRATION
PNEC PREDICTED NO EFFECT CONCENTRATION
REACH REGISTRATION, EVALUATION AND AUTHORISATION OF CHEMICALS (NEW
EUROPEAN CHEMICALS REGULATION)
SME SMALL AND MEDIUM SIZED ENTERPRISES
SVHC SUBSTANCE OF VERY HIGH CONCERN
VPVB VERY PERSISTENT AND VERY BIOACCUMULATIVE SUBSTANCE

ANNEXES
ANNEX 1: LINKS TO SUBSTANCE LISTS
Candidate list for authorization of substances of very Ospar list of substances for priority action:
high concern http://www.ospar.org/content/content.asp?me
http://echa.europa.eu/chem_data/candidate_list_table_ nu=00940304440000_000000_000000
en.asp
Stockholm Konvention POPs:
Priority and priority hazardous substances of the Water http://www.pops.int/documents/convtext/convtext_en.pdf,
Framework Directive http://chm.pops.int/
http://ec.europa.eu/environment/water/water-framework/
Montreal Protokoll:
priority_substances.htm
http://ozone.unep.org/
Helcom list of substances of possible concern:
Kyoto Protocol
http://www.helcom.fi/Recommendations/en_GB/rec19_5/
http://europa.eu/legislation_summaries/environment/tack-
Ospar list of substances of possible concern (Datenbank ling_climate_change/l28060_en.htm
zum Suchen von Stoffen) und Liste zum herunterladen:
Endocrine disrupting chemicals
http://www.ospar.org/content/content.asp?me
http://ec.europa.eu/environment/endocrine/documents/
nu=00950304450000_000000_000000
sec_2007_1635_en.htm
ANNEX 2: PBT/VPVB-CRITERIA OF REACH ANNEX XIII
cRiteRion Pbt VPVb
Persistence
half-life in marine water or > 40 days > 60 days
half-life in freshwater or estuaries or > 40 days > 60 days
half-life in marine sediments or > 180 days > 180 days
half-life in freshwater sediments > 120 days > 180 days
or estuarine sediments or
half-life in soil > 120 days > 180 days
bioaccumulation potential
bioconcentration factor > 2 000 > 5 000
toxicity
concentration, below which no effects < 0,01 mg/l nicht anwendbar
are observed in marine or freshwater
organisms (no-observed effect concentration — noec)
substance is
or carcinogen (cat 1 or 2),
mutagen (cat 1 or 2) or
reprotoxicants (cat 1, 2 or 3)
classification according to dir 67/548/eec t, R48 or xn, R48

ANNEX 3: LINKS TO DATA BASES AND EVALUATION INSTRUMENTS
3.1 PROBAS Database of the Federal Environmental using the material consumptions necessary for their
Agency manufacturing or supply. On the MIPS web pages an
In the Probas database, information on different excel file is provided for structuring respective data
materials and processes are compiled. For a defined collection. Furthermore, lists with material intensities
reference amount of a product (e.g. 1 kg of copper), the of different raw materials and chemicals are given.
required inputs are provided (energy, materials, water).
The energy consumption is expressed as aggregated Related to the current guide, the values for material
values (KEA/KEV), which describe the cumulated energy and water consumption can be used. Energy consump-
consumption along the supply chain (table “resources”). tions and the renewability of raw materials are not
The water consumption can be extracted from the table considered by MIPS. However, selfstanding evaluations
“inputs”. In the table “wastes” the amounts of waste can be done.
produced along the supply chain are listed. http://www.wupperinst.org/de/projekte/themen_online/mips/
http://www.probas.umweltbundesamt.de/php/index.php index.html
3.2 MIPS-concept of the Wuppertal institute for climate, The Directorate Research of the European Commission
environment and energy GmbH and further LCA tools provides tools and data bases for lifecycle analyses on
MIPS stands for “material input per service unit”. Ac- their website free of charge.
cording to this concept, the environmental impacts of http://lca.jrc.ec.europa.eu/lcainfohub/directory.vm
a substance, material, product or service are calculated
ANNEX 4: FURTHER PUBLIC AVAILABLE SOURCES OF INFORMATION
This annex describes some sources for additional infor- implementation of best available techniques. They are
mation. It is not complete, however if offers valuable documented for many sectors in the so-called BREF
help to work with the sustainability criteria. In many documents, see http://eippcb.jrc.es/reference/
cases sector-specific information is available. For this
the respective associations should be contacted. Sector-specific lists of problematic substances
The “Global Automotive Declarable Substance List”
Review on sustainable chemistry of the automotive industry is a corporate instrument
Das Hintergrundpapier des Umweltbundesamtes zur for the management of problematic substances. It is
Nachhaltigen Chemie gibt einen guten Überblick über publicly available (www.gadsl.org)). Lists of problematic
die Vielfalt der Themen, die zur nachhaltigen Chemie substances which can be relevant for all branches are
gehören. Es kann heruntergeladen werden von der documented in Annex I of this guidance.
folgenden Internet-Seite: http://www.umweltbundesamt.
de/uba-info-medien/mysql_medien.php?anfrage=Kennu Data bases on hazardous substances
mmer&Suchwort=3734. Examples for public available data bases on hazardous
substances are “Der gemeinsame Stoffdatenpool von
Approaches to set sector-specific priorities in risk Bund und Ländern” (http://www.gsbl.de/index.html)
management and the European data base on classification and label-
The HACCP concept (“Hazard Analysis and Critical Con- ling, Joint Research Center, Ispra, Italy (http://ecb.jrc.
trol Point” has been developed especially for the food ec.europa.eu/classification-labelling/search-classlab/).
industry. However its principles can be applied in other
sectors of industry, also. More details can be found at Identification of risk management measures for work
http://www.bfr.bund.de/cm/234/fragen_und_antwor- places
ten_zum_hazard_analysis_and_critical_control_point__ The “Easy-to-use workplace control scheme for ha-
ha ccp__konzept.pdf. zardous substances” (Einfaches Maßnahmenkonzept
Gefahrstoffe, EMKG) of the Federal Agency for Occupa-
Sector-specific documentation of best available tech- tional Health and Safety supports enterprises’ decisions
niques on risk management measures to ensure safe use of sub-
Saving of ressources and costs can be achieved by stances and mixtures. It is based on a limited amount

of information which are available in companies (e.g. the supply chain with several recommendations on the
in safety data sheets (for details see http://www.baua. implementation in practice. The guidance and the case
de/de/Themen-von-A- Z/Gefahrstoffe/EMKG/EMKG__con- studies can be downloaded from the following webside:
tent.html). http://www.vci.de/default~cmd~shd~docnr~125022~l
astDokNr~102474.htm (german version) / http://www.
Guidance on chemical safety assessment, exposure cefic.org/Files/Publications/Doc-1-Part-1-to-3-Practical-
assessment and risk characterisation: Guidance-final.pdf (english version).
The explanation and support of a comprehensive assess-
ment of emissions along the lifecycle of a substance is Exposure estimation tools
not possible in this guide. However, publications on this Several instruments have been developed to support the
topic can be found on the web in much detail. tasks of exposure estimation and risk characterisation.
An overview is given in Part IV of the above mentioned
The European Chemicals Agency publishes an compre- REACH Practical Guide. Last year the second version of
hensive Guidance on Information Requirements and the exposure estimation tool ECETOC TRA (“Targeted
the Chemical Safety Assessment. It describes – besides Risk Assessment”) has been published. It is available for
others – the methods for as sessing exposures and cha- free (http://www.ecetoc.org/tra).
racterizing risks from the use of chemicals46. ECHA pu-
blishes further guidance on all topics related to REACH Guidance for Substitution
(see http://guidance.echa.europa.eu/guidance_en.htm). Guidance for substitution is given in a publication of
the Bundesanstalt für Arbeitsschutz und Arbeitsmedi-
For the structured communication on uses the so called zin (BAUA) (Technische Regel Gefahrstoffe (TRGS) 600,
“Use Descriptor System” has been developed in the www.baua.bund.de/nn_78960/de/Themen-von-A-Z/Ge-
framework of REACH. It is described in Part R12 of the fahrstoffe/TRGS/pdf/TRGS-600.pdf). A good overview on
ECHA Guidance on information requirements menti- the topic is given in the publication of Lißner and Lohse
oned above. (Lißner, L.; Lohse, J. (2006); Braucht Substitution mehr
Staat oder mehr Markt? In: UWSF – Z Umweltchem
The VCI REACH guidance for practitioners introduces to Ökotox 18 (3) 193 – 200).
the topics exposure assessment and communication in
ANNEX 5: CLASSIFICATION OF SUBSTANCES AND SAFETy INFORMATION IN THE SUPPLy CHAIN
Three of the eight substance-specific criteria described The placer on the market may choose which of the sys-
in chapter 2 of this guidance are based on the existing tems he applies or even if he uses both simultaneously.
classification of a substance (physico-chemical proper- By 2015, all substances are to be classified and labelled
ties, human toxicity and ecotoxicity (c.f. chapters 2.1.2, only according to the CLP-regulation
2.1.3 and 2.1.4)). This information is to be generated by
manufacturers and importers and is normally availab- Under REACH, manufacturers of substances are re-
le at the end users of chemicals in form of safety data quired to compile and/or generate information in the
sheets, REACH information or product labels. Informa- scope of its registration. The extent of information de-
tion on the dangerousness for the environment (c.f. pends on the registered annual volume. Parts of this in-
Chapter 2.1.4) and on the mobility (c.f. Chapter 2.1.5) formation are to be forwarded to the downstream users
is normally contained in the safety data sheet as well. of substances and mixtures via the safety data sheet.
Therefore, some basic information and legal back- The information is to be provided in accordance with
ground is given on this information source. REACH article 32 and the results of tests and studies are
to be provided directly, if possible. Information which
By the end of 2010, substances may be either classified is not (yet) available or not legally required for the
or labelled according to the EU Dangerous Substances registered tonnage as specified in the Annexes VI – XI
Directive (67/548/EEC or the German TRGS 200 respec- of REACH should be indicated in the safety data sheet
tively) or according to the European Classification and (remark “not tested” or “information not available”).
Labelling Regulation (CLP-regulation, EC/1272/2008).
44 leitfaden nachhaltiGe chemikalien

Downstream users of substances and mixtures recei- mixtures should be consulted to clarify the information
ve respective safety information from their suppliers. basis47. This is particularly relevant when alternatives
In the transition period of REACH, they should pay are compared in the context of assessing substitution
particular attention to new information on a substance possibilities.
as such or contained in mixtures, especially after its
registration. If a substance or mixture is not classified as dan-
gerous48, in principle no safety data sheet must be
The lack of information about the properties of subs- provided49. However, other properties of a substance or
tances and mixtures in the safety data sheet and / or mixture (e.g. dustiness) may require the communication
those marked with “not applicable” are not transparent, of risk management measures to ensure safe handling.
as it is not clear if tests have been performed to show According to REACH article 32, suppliers/manufacturers
that a dangerous property is not present or if no tests have to communicate such information. The format for
sufficient for a classification have been performed. If forwarding this information is not legally defined.
information is ambiguous, the supplier of substances or
ANNEX 6: FURTHER INFORMATION ON THE EMISSION POTENTIAL
Relevance of the emission potential Depending on the type of substance and its uses, each
The emission potential expresses, what amount of a sub- of the lifecycle steps may occur once, more than once
stance is lost or released during its lifecycle and what or not at all. Some substances are used in different
exposures and pressures for man and the environment applications and hence, several lifecycles should be
may result. Emissions are normally assessed for single assessed.
substances, rather than for several substances at the
same time. If mixtures are assessed, the emission poten- According to the European chemicals regulation
tials are to be evaluated separately for its components, REACH, for all substances registered in amounts ex-
reasonably for those with the highest mobility and / or ceeding 10 t/a and which are classified as dangerous,
the most severe dangerous properties for humans or the an emission estimation and exposure assessment is to
environment. be performed. The instruments supporting this assess-
ment are for example a system to describe uses in a
Emissions from products and processes can be reduced standardised way (use descriptors51) and simple models52
by implementing risk management measures, which for estimating emitted amounts of a substance from
should be considered in the assessment of the emission processes and products.
potential, if the respective information is available in
the company50. The aim of the so called chemical safety assessment
under REACH is the identification of risk management
Lifecycle of a substance measures, which are necessary to ensure safe handling
In order to review the emission potential of a substance and use of a substance along its entire lifecycle, inclu-
(as such or as a component of a mixture or article), all ding the use in articles and the waste disposal stage.
of its uses need to be considered. Normally, each use
is a sequence or combination of the following lifecycle
stages:
> Manufacture (or import)

> Formulation / mixing of mixtures (frequently several
mixing steps in one or several companies)
> Use of a mixture in processes (as processing air or for
the manufacture of articles, in which the substance is
integrated into)
> Use of the article (service life)
> Disposal of the articles and production wastes, which
are produced along the lifecycle.
leitfaden nachhaltiGe chemikalien 45

ANNEX 7: SUBSTITUTION
When deciding on substitution, the replacement of For non-chemical alternatives, but also if alternatives
critical substances with less critical alternatives, as well are used, further risks have to be considered:
as other measures such as a different product designs or > If a substance is replaced by technical measures, risks
organisational and technical measures in the produc- for workers may shift from chemical stress to physical
tion process are relevant. In any case, various factors or other stress53
influence which option is most efficient or feasible in a > Substitution may result in the loss of safety of the pro-
specific context. In the following, some of these factors duct, which could be an indication for a worse quality
are briefly introduced. For detailed information, specific (e.g. higher flammability due to the abandonment of
literature on substitution should be consulted. flame retardants).
> A changed (substance) design could deteriorate the
Maintaining or improving product quality manageability of products.
The use of alternatives should improve the quality of a
product towards more sustainability; in no case should Technical preconditions in the own company and at the
it worsen the product quality. The qualities to maintain customers’
or improve are e.g. the lifespan of the product, safety The alternatives for non-sustainable substances have
functions during use, the practicality of a product or a to be applicable in existing technology, not only inside
product’s weight (material input). own production processes, but also at the customers’.
In particular in sectors where complex and very fast
If the product design is changed and thereby the use production processes occur (e.g. newspaper printing) or
of a critical substance is phased out (e.g. constructive very complex articles are manufactured (e.g. electronic
flame retardation instead of the use of chemical flame devices), production processes and machines are fine-
retardants) sustainability can be realised through the tuned to the use of particular chemicals. In substitution
adoption of that change in other products. This could processes, the entire supply chain and all related condi-
happen either as a “technological spill over”, where a tions and technical requirements are to be assessed.
systematic change is used across different technologies
or simply through the integration of the changed pro- Economic issues
duct into complex articles as a component. The substitution of substances is connected to diffe-
rent types of economic risks: the technical feasibility,
The quality of products is sometimes defined by the the frequently missing information on the dangerous
customers, who may demand certain characteristics or properties of substitutes (and resulting difficulties in
qualities. In these cases, the question of the availability comparing alternatives), the financing of research
of alternatives is limited by these demands - sometimes activities, the practical and technical implementation
with very low tolerances. On the other hand, if custo- of substitution, as well as the risk of lower acceptance
mers define their quality criteria with respect to the of new products on the market. Substitution may at the
content or the absence of certain substances, the search same time offer many opportunities to increase product
for alternatives is obviously welcome and not limited by quality, en force approaches for sustainable innovation
any conditions. and thereby improve the market position or enter new
markets.
No shift of risk, no increase of total risk
If non-sustainable substances are replaced by other Each enterprise has to assess substitution issues for
substances, any risks for human health or the environ- itself, balance risks and opportunities connected with a
ment should be carefully observed that they are not substitution and make a respective decision.
increased. This can be ensured if the substitute has less
dangerous properties for human health and the envi-
ronment (c.f. Chapter 2.1.3 and 2.1.4), if it less mobile
(c.f. Chapter 2.1.5) and / or is used in significantly lower
amounts (c.f. Chapter 2.2.3).
46 Guide on sustainable
leitfaden nachhaltiGechemicals
chemikalien
ANNEX 8: BENEFIT POTENTIALS
The benefit potentials can be allocated to different are Environmental benefits

as, which are briefly described in the following. Environmental benefits are realised by improving pro-
duct quality (prolonged lifespan, resource savings) and
Quality of (end) products frequently overlap with the previously mentioned items.
The functionalities of substances54, which improve Further environmental benefits of substances can be
product qualities in the sense of sustainability, are for seen in that they (contribute to) improve the quality of
example functionalities that: the environment. Some examples are environmental re-
> Prolong the lifespan (e.g. reduced deterioration due mediation technologies: chemical wastewater cleaning,
to weathering by the use of UV-stabilisers or corrosion use of chemicals for the remediation of environmental
inhibitors); damage. Further benefits regarding sustainability are
> Reduce the material consumption for the manufactu- always connected to a chemical, when it is important
ring of a product (e.g. lower material density through for the function of a product that replaces technologies
the use of nanomaterials); carrying heavy environmental burdens (e.g. silica in
> Enhance safety or enlarge the benefits of other solar cells instead of energy production based on fossil
products (e.g. lubricants increase safety and reduce fuels like coal).
abrasion of machinery).
Economic benefits
Societal benefits A sustainable decision on the manufacture and use of
To evaluate the societal benefits of a substance, the chemicals must also consider the economic consequen-
function of the end product is to be assessed as well as ces for enterprises. Normally, it is not possible to imme-
the potentially caused impacts on human health. For diately phase out the production or use of a chemical,
example, the societal benefit of fragrances in erasers, which has been evaluated as not sustainable. The eco-
CDs or similar articles can be questioned. However, a nomic survival of companies is to be ensured and may
significant benefit can be seen in the use of silver in relativise the non-sustainability of chemical. However,
textiles which makes clothes better tolerable for per- sustainability of products should gain a higher impor-
sons with neurodermatitis. The use of biocides in metal tance in the long-term goals of companies.
working fluids improves workers’ health by preventing
or at least significantly reducing the growth of pathoge-
nic bacteria.
For the reflection of societal benefits, the following

questions should be answered:
> What qualities does a substance add or contribute to
an end product?
> What benefit does society have from the existence of
that property? Are there indications that the function
is wanted or objected to?
> Does the property enhance the health conditions of
consumers and workers?
SOURCES: consumption).
45 The PBT/vPvB criteria of Annex XIII are currently under revision 51 C.f. the guidance document by the European Chemicals Agency on
46 The guidance is available at the European Chemicals Agency: http:// information requirements and the chemical safety assessment, part D.
guidance.echa.europa.eu/guidance_en.htm This guidance is available on the website of the European Chemicals
47 If a substance is not classified because no data are available, at a later Agency (http://guidance.echa.europa.eu/guidance_en.htm.).
stage it can turn out to be of higher concern than the substance to be 52 E.g. ECETOC TRA Version 2. An easy to understand description of instru-
substituted. It would neither be sustainable nor economically reasonable ments on exposure assessment can be found in the indepth chapter on
to take a decision based on an incomplete data basis. In this case it is to exposure assessment of the REACH guide for practitioners (available on
be decided if new data are awaited or if a substitute is excluded due to the web at http://www.vci.de/default~cmd~shd~docnr~125022~lastDok
lack of data, if own data are generated or substitution is implemented Nr~102474.htm).
despite the lack of information. 53 For example can solvent-based paints be replaced if a drying installation
48 According to REACH, a safety data sheet has to be provided also for is used. The dryer my expose workers to higher temperatures and po-
PBTs/vPvBs and substances on the candidate list for authorisation, even tentially higher levels of noise by the exhaust gas system of the drying
if they are not classified. installation.
49 Unless the substance is of very high concern and listed on the candidate 54 If the sustainability of materials or end products is evaluated, further
list for authorisation. and other criteria are relevant as compared to assessing chemicals
50 In order to remain manageable, this guide is limited to a first and rough only, e.g. the possibility to repair or dismantle products for recycling.
estimation. Furthermore, emissions with view to sustainability, even if The following explanation is limited to functionalities of sustainability,
they do not lead to exposures because of appropriate risk management which can be evaluated and influenced by manufacturers and users of
measures, should be prevented, in order not to lose substances (resource chemicals.
leitfaden
Guide on
nachhaltiGe
sustainable
chemikalien
chemicals 47
EDITORIAL INFORMATION
GUIDE ON SUSTAINABLE CHEMICALS Publisher:
A decision tool for substance manufacturers, Federal Environment Agency
formulators and end users of chemicals Wörlitzer Platz 1
D-06844 Dessau-Roßlau
April 2011
Phone: 00-49-(0)340 – 2103 – 0
Antonia Reihlen, Ökopol GmbH Email:
Dirk Bunke, Öko-Institut e.V. [email protected]
Rita Groß, Öko-Institut e.V. Internet:
Dirk Jepsen, Ökopol GmbH www.umweltbundesamt.de
Christopher Blum, Umweltbundesamt
www.fuer-mensch-und-umwelt.de
Öko-Institut e.V.,
Geschäftsstelle Freiburg Layout:
Postfach 17 71 Studio GOOD, Berlin
79017 Freiburg, www.studio-good.de
www.oeko.de,
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Nernstweg 32 – 34,
D-22765 Hamburg,
www.oekopol.de,
Phone: 00-49-(0)40 – 39 100 2 – 2
Umweltbundesamt,
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www.umweltbundesamt.de,
This publication is available free of charge at:
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Service phone: + 49 (0) 340 21 03 - 66 88
Service fax: + 49 (0) 340 21 03 - 66 88
This brochure can be downloaded from:

http://www.umweltbundesamt.de/uba-info-medien-e/4169.html
Photographs:
p. 2/3, p. 8/9, p. 19, p. 21, p. 25, p. 30, p. 34/35, p. 36/37:
www.shutterstock.com
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GUIDE ON

page 2-7 page 8-33 page 34-37 page 38-39 page 40

page 4 page 5 page 11

page 4 page 5 page 24

page 5 page 6 page 41 page 42-47

The result of using

Sustainable chemistry comprises of many aspects. They range

4 GUIde On SUSTAInAbLe ChemICALS

GUIde On SUSTAInAbLe ChemICALS 5

figure 1: inTerlinks beTween criTeria

6 Guide on sustainable chemicals Guide on sustainable chemicals 7

The criteria for the selection of sustainable chemicals should

figure 2: options to aCt depending on the results of the evaluation

cRiteRia Red YelloW GReen White

substance on list substitution

dangerous Pc Properties substitution Risik management

dangerous for the environment

Request standards from sup-

10 Guide on sustainable chemicals

If the function of a product requires problematic

The sustainability of chemicals based on their intrinsic

Guide on sustainable chemicals 11

2.1.1. Mentioning on lists of problematic substances Applicability of criterion

Unfortunately, there is not “the one and only”, but Evaluation

Relevance indicator substance lists

12 Guide on sustainable chemicals

Note: If information is missing to judge on this criterion,

the colour white should be assigned. This indicates that

criterion: substance is explosive, substance is flammable substance has no r-phrase

information should be gathered.

*: C&L according to 67/548/EEC, Classification and labelling according to Directive 67/548/EEC

***in addition to table 2::

Guide on sustainable chemicals 13

Applicability of criterion Evaluation

14 Guide on sustainable chemicals

Note: If information is missing to judge on this criterion, the colour white

Furthermore, PBTs and vPvBs can accumulate in the Evaluation

Guide on sustainable chemicals 15

evaluation red YelloW Green

16 Guide on sustainable chemicals

evaluation Red YelloW GReen

sub-criterion: Release potential high solubility medium solubility low solubility

indicator solubility in water > 10 mg/l 10 – 0,001 mg/l < 1 µg /l

sub-criterion Release potential Very dusty dusty not dusty

the following sub-criteria are not relevant for manufacturers of substances

indicator: use in mixtures. substance substance is not used in embedding of substance in

Guide on sustainable chemicals 17

table 7: uSe and evaluation of the criterion “oriGin of raW MaterialS”

indicator no management systems and environmental management Good (documented) manage-

18 Guide on sustainable chemicals

Relevance Information basis

Guide on sustainable chemicals 19

table 8: uSe and evaluation of the criterion “GreenhouSe GaS potential”

evaluation red YelloW Green

indicator aggregated green- > 50 1 – 50 <1

20 Guide on sustainable chemicals

The following table provides as a rough indication some

chapter 4.1 of the background paper of the German environ-