Baltic Breakfast: Concept developed at Stockholm University incorporated in new EU strategy
2020.12.09: “A unique document”. Scientists at Stockholm University and KTH Royal Institute of Technology praised the new EU chemicals strategy at the last Baltic Breakfast webinar and were especially delighted to find their own recommendations included in the document. However, some important linkages were also pointed out as missing.

Professor Ian Cousins and moderator Hanna Sjölund
Professor Christina Rudén from the Department of Environmental Science at Stockholm University started off the webinar by sharing her views on the new EU strategy.
– When I started reading it I got a little bit excited already at the first row, because it said ‘toxic-free environment’, she said.
In Sweden, non-toxic environment has been an environmental objective for a long time, but the expression has been controversial in Europe and among different stakeholders.
– To me this indicated something new. And as I kept reading I got quite enthusiastic, because I actually think this is a really good policy, Christina Rudén continued.
Chemical control expanded
The new EU Chemicals Strategy for Sustainability Towards a Toxic-Free Environment was long awaited when presented by the EU Commission on 14 October this year. The strategy rests on two major legs: encourage innovation, and protect health and the environment.
With the aim of increasing the safety of children, consumers and workers, the strategy wants to ensure that consumer products don’t contain chemicals that can cause cancer, gene mutations or are persistent, bioaccumulative and toxic (PBT). But even chemicals that affect the immune system, the neuro- or respiratory systems, or are toxic to a specific organ, are mentioned.
– The strategy expands the scope of chemical control. That is new and important, says Christina Rudén.

Professor Christina Rudén is happy to see that the problem with combination effects of chemicals is addressed in the new EU strategy.
Problem with mixtures pointed out
She has frequently drawn attention to the lack of risk management of chemical mixtures that are used today. The new chemicals strategy points at this problem by stating that it should be assessed how to best introduce a mixture assessment factor to the REACH regulation. It also states that combination effects should be considered in other legislations, such as those regulating water, food and toys.
– A mixture assessment factor is a good pragmatic way to deal with mixtures and co-exposures. I’m particularly glad to now see this being addressed in the new strategy, since it was something we also suggested in our report to the Swedish government, says Christina Rudén.

Although enthusiastic about the new strategy, Professor Christina Rudén also identifies important pieces that she thinks are still missing in the new strategy.
Welcome incorporation of ‘essential use’ concept
Professor Ian Cousins, colleague to Christina Rudén at the Department of Environmental Science at Stockholm University, also found his recommendations applied in the new strategy. The concept of ‘essential use’ of chemicals was developed at Stockholm University, as a guiding tool in the process of phasing out hazardous PFAS. The concept was described in a scientific paper only last year, but has now been incorporated throughout the new strategy document.
– It was astonishing that it was rapidly taken up into European chemicals policy already this year, says Ian Cousins.
PFAS is a group of high persistent chemicals. Once released, they stay in the environment for a very long time, and some of them are known to be toxic. Although these chemicals may have a critical role in products that are important to us, the scientists also found that many of the uses of PFAS were rather non-essential.
– We believed that there were many non-essential uses that could be rapidly phased out without developing alternatives, says Ian Cousins.
Examples of such non-essential uses were found in a wide range of cosmetics, like mascaras and face creams, where PFAS didn’t seem to have an important function.
– When retailers and brands were confronted they rapidly agreed to phase put PFAS from the products. This was clearly a non-essential use since they could phase them out so quickly.

Professor Ian Cousins and his collegues developed the concept of 'essential use' when studying PFAS, a concept that has now been picked up by the EU Commission and used in the new Chemicals Strategy.
Concerns regarding implementation
Mikael Karlsson, Associate Professor at KTH Royal Institute of Technology, agrees with the overall praise of the new EU strategy, but rasies some concerns regarding the implementation and what actual effects it may have.
– This strategy is unique, but how much improvement will we see in the Baltic Sea for example?, he says.
One of the things that concerns him is the legislative landscape in which chemicals are regulated. We can distinguish between producer-oriented legislation, like REACH, and environmentally oriented legislation, like the Water Framework Directive - between which there are no linkages, says Mikael Karlsson.
– If you find a pollutant in the marine environment there is no automatic mechanism making sure that the producer-oriented legislation is reacting. This key problem is not dealt with in the strategy, as far as I can see.

Mikael Karlsson would like to see greater changes in the legislative landscape of chemicals, but still think the new strategy is promising.
"Science and reason will win"
Mikael Karlsson also points out that the overall legislative approach, how we look at the producer-public relationship, has not changed in any fundamental way with this new strategy. As an example, the REACH regulation still makes it easy to introduce new substances on the market - but very difficult to ban them.
– The burden of proof for authorization and restriction still rest with the public side. In that way, this is not a precautionary piece of legislation, he says.
Overall, however, Mikael Karlsson is looking positively at the new strategy document and tdescribes it as 'unique'.
– It is promising, but far from realized yet. I’m hoping for the best. Eventually science and reason will win again, and in extension to that we will have a toxic-free environment, ha says.
Text: Lisa Bergqvist
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Last updated: 2025-09-18
Source: Östersjöcentrum