Regulatory Affairs Chemical strategy for sustainability More info Contact Luminita barbu EDANA has been active since the beginning of the publication of the Chemical Strategy for Sustainability and already contributed to the discussions on the essential uses concept. The industry view is that products with a demonstratable health benefit and chemical use supporting the objectives of the European Green Deal and Sustainability Goals (e.g., those which have an impact on the durability of products) should be included in a “guidance of harmonized set of criteria on “essentiality” to support ECHA’s assessment”. Essentiality should not be looked at in isolation, it needs to be determined based on fair, verifiable facts/data in a transparent process, and not based on opinion. It also needs to be addressed with a very high level of granularity within each sector (an almost product-by-product consideration) to be correct, fair, proportionate, and valid. EDANA recommends removing the “pre-decision at political level” step and keeping the current legal process which adequately address risk management of chemical i.e., ECHA RAC and SEAC assessment of Authorization or Restriction exemption, but with some adaptations e.g., develop guiding harmonized set of criteria on “essentiality” to be considered with all the other usual parameters, in a holistic and nuanced way, when performing socio-economic analysis. A decision on essentiality is such a complex, multi-dimensional, and even subjective concept that it can only be addressed by a large multifunctionalteam involving different stakeholders with different expertise such as EU Commission, Member State Committee, scientists, industry, economists, NGOs representing various points of view of society etc.