Through a survey with European companies and expert interviews we study how REACH authorisation affects the phase-out of hazardous chemicals focusing on trichloroethylene, a well-studied solvent used in metal parts cleaning. We find that most of the firms have substituted trichloroethylene by perchloroethylene, which has similar chemical characteristics. This allows them to continue to use the same machines and routines at low costs. Although perchloroethylene is only classified as a suspected rather than a proven carcinogenic substance in Europe, the “improvement” as the result of much regulatory effort must be considered fairly limited, particularly in the light of less hazardous alternatives being used on the market for a long time. Our survey shows that the REACH authorisation process has some effect. Many firms cited as their main reason for substitution that they wanted to avoid the renewed application process. Still, the fact that many firms report using old machines reinforces the impression that some firms are not feeling enough pressure to modify routines and engage in a more fundamental substitution process.
The results illustrate the limited effectiveness of a substance by substance approach in chemical risk management. When companies can substitute chemicals of concern to substances with similar chemical characteristics, the health and environmental objectives of chemical regulation are not achieved. An important policy conclusion is that additional incentives need to be introduced in order to realize the ambition of a non-toxic environment in the European Chemicals Strategy for Sustainability. Increased use of measures targeting broader groups of structurally similar hazardous chemicals, in combination with fees that incentivize substitution, are promising avenues for a more sustainable European chemicals strategy.
