The ANEC position paper on chemicals in consumer products is based on two studies commissioned by the ASI Consumer Council. A further study - part 3 - was finalized in December 2012 outlining how some of the current regulatory gaps regarding chemicals in products could be filled.

Key issues to be addressed

Image of test tube

As highlighted in the ANEC position paper and the ASI Consumer Council studies, specific European chemical performance requirements for products which consumers get into contact in their daily lives are either

  • inadequate because of serious gaps (food contact materials – only plastics materials comprehensively regulated), absence of clear-cut limits (medical devices) or lack of ambition (toys); or
  • (almost) not existing for most products of our daily lives (clothing, furniture, floor coverings, personal protective equipment, child care articles, sports equipment, construction products, interior of cars, ….).

REACH does not compensate for these deficits because articles are hardly covered, the restriction path is laborious and related to single substance risk assessments (generic bans of e.g. CMR substances in articles are not possible), an approval system for chemicals in articles is not possible (positive lists as in cosmetics and food contact legislation), non-toxic effects or parameters cannot be addressed (e.g. organoleptic parameters).

Regulatory action is often based on ad-hoc action where problems have been identified. Similarly, a systematic monitoring of chemicals in products does not take place. Lacking clear-cut regulatory provisions, market surveillance is rather limited. Information provision requirements for chemicals in articles also hardly exist. As a result the knowledge concerning the occurrence of chemical used in articles is rather limited.

Different options exist for enhancing the legal framework for chemicals in products. These include incorporation or strengthening of chemical provisions in existing product regulations (e.g. for toys), implementation of new product regulations (e.g. for textiles) or using new or expanding existing horizontal instruments to address chemicals in products. In many cases some kind of specification already exists and could be adopted at the European level.

The conference aims at discussing these issues in order to identify the way forward. The presentations are supposed to address the gaps and how they can be filled.

In June 2014 the up-to-date ANEC position paper 'Hazardous chemicals in products - The need for enhanced EU regulations' has been released. A summary is also available.

For more information, please contact ANEC Secretariat by email at or by phone at +32 (0) 2 743 24 70.