Knowledge advantage in SSbD offers opportunities for Dutch chemical companies

The regulatory landscape for the chemicals sector is evolving rapidly. In addition to existing frameworks such as REACH and CLP, new European regulations are emerging, including the Corporate Sustainability Reporting Directive (CSRD) under the Green Deal. This mandates companies to report on their sustainability practices. The Ecodesign for Sustainable Products Regulation (ESPR) also introduces tools like the Digital Product Passport, which will provide insights into the composition, sustainability, and reparability of products.

“There is a growing awareness that we only have one earth. Climate impacts and human health considerations are now being given greater weight in European regulations,” says Hedwig Braakhuis, Senior Toxicologist at TNO. She studies the risks of new substances and materials from the Safe and Sustainable by Design (SSbD) perspective.

Healthy balance

The implementation of laws and regulations for the Dutch market lies with the Ministry of Infrastructure and Water Management. René Korenromp is policy officer for Substances there. In recent years, he has focused on the implementation of the CSS with a major focus on SSbD. “IenW is committed to a healthy and safe living environment. That is why we support the sustainable Chemicals Strategy and the Green Deal, as well as the principles of SSbD. Our aim is to prevent companies from introducing substances or developing applications that society and businesses may later regret. PFAS for example, ‘forever chemicals’, which have also been used in disposables, and has turned out to be highly undesirable. Legislation alone can never fully prevent such outcomes, as regulations inevitably lag behind the vast number of chemicals and materials

entering the market. At the same time, we do not want excessive regulation to stifle innovation. Achieving a healthy balance is what matters most. That is why we think it is important for industry to think critically about the safety and sustainability of innovations from its own motivation. SSbD can be very valuable in this. Moreover, this approach offers great economic opportunities for the Netherlands, which is already progressive in terms of innovations and standards in chemistry. At companies, at the RIVM, at knowledge institutions such as TNO, but also at Dutch consultants, there is a lot of knowledge.”

Level playing field

Despite the opportunities, companies also see obstacles to getting started with SSbD, notes Hedwig Braakhuis: “In conversations, we often hear that while companies embrace the concept of SSbD, they are unsure of how to apply it successfully. Another challenge is the current economic climate, which is unfavourable for the chemical industry. Many companies are already struggling to maintain operations and comply with existing regulations.

They are critical of the investments required for SSbD and seek greater certainty regarding the return on investment. Additionally, there is a strong need for a level playing field. Companies that have made substantial, fair investments to make their products more sustainable want to see meaningful returns.”

More clarity

René Korenromp recognises the challenges Braakhuis outlines. “We have conducted research among SMEs. This shows that, particularly among companies with sufficient equity capital, there is interest in SSbD and in-depth investments. In contrast, companies relying heavily on venture capital face greater pressure from investors, with a stronger focus on short-term returns.

Nevertheless, in general, chemical SMEs are positive about SSbD but are seeking clarity: less bureaucracy and regulations that are better aligned. This is why we are exploring how to integrate regulations for the circular economy and SSbD. We are taking a similar approach with CSRD: examining how companies can align their sustainability efforts with SSbD. We have asked TNO to guide this research, drawing on their expertise in SSbD.”

Expertise centre for SSbD

Another important step IenW is taking to support businesses is the commitment to establishing an expertise centre for SSbD. Korenromp explains: “This centre aims to bridge the gap between industry, science, and policymakers. Currently, there is still a significant disconnect between the complex methodologies and calculation tools researchers develop for SSbD and the practical realities faced by many companies that need to implement them. From our perspective, the expertise centre will provide harmonised support to illustrate what an innovation process aligned with SSbD principles could look like. For IenW, what truly matters is that companies can transparently justify the decisions they make.”

Experience comes first, then regulations

In the meantime, the European Commission's Joint Research Centre has prepared a first draft for an SSbD framework. Hedwig Braakhuis explains:

“The industry regards this framework as a gold standard. At the same time, companies struggle to apply these guidelines within the innovation process due to the extensive amount of information required. It would be beneficial if the framework were designed more iteratively, offering greater flexibility. Iterations can help to better integrate the draft framework into the design process.

Flexibility is particularly important for enabling the use of AI techniques to predict adverse effects in advance. Additionally, the framework could be better aligned with CSRD and ESPR policies.”

Korenromp adds: “In the future, this framework could serve as the basis for regulations, or we might optimise existing regulations to encourage adherence to SSbD principles. However, the biggest mistake we could make right now would be to move directly to regulation. For the time being, we should first gain experience with the concept.”

Start small

To that end, companies can already start using SSbD today, says Korenromp. “When I was involved in the development of Life Cycle Assessment (LCA) as an environmentalist 30 years ago, I often heard that more data was needed to make proper analyses as a basis for sound decisions. I fear that discussion will always persist. We shouldn't fall into the same trap with SSbD.” Hedwig Braakhuis agrees. “SSbD often appears complex, but at TNO, we have developed a straightforward method to facilitate a low-threshold start. With a short questionnaire, you can quickly assess whether a product or substance might pose risks to humans or the environment under current and upcoming regulations. This approach allows you to identify many potential risks early on with a quick check. Besides, it doesn’t have to be perfect: start with the basics. For example, screen your portfolio for substances that perform poorly in terms of safety or sustainability, and address those first. Start today and improve step by step.”

Learn more? Please contact us.