In our answer to the European Commission’s public consultation on the Sustainable Products Initiative, Stockholm University Baltic Sea Centre highlights the need for full disclosure of chemicals content in articles, i.e. consumer products, such as clothes, electronics and furniture. In this text the term consumer product is used.

Today, information on the chemical composition of consumer products is very scarce, making it difficult to understand which potentially hazardous chemicals are being released to the environment. The lack of chemical ingredient lists also hinders the assessment of human indoor exposure and forms a barrier to implementing a circular economy with non-toxic material cycles.

Neither do economic actors have adequate and reliable information on the sustainability of consumer products, nor their chemicals content. There is an urgent need for standardised methods and legal incentives to increase the availability of information on chemicals in consumer products for authorities, researchers, and consumers.

We have earlier highlighted the need for increased transparency on chemicals in consumer products in a policy brief, which we now provide as supporting information.

One of the options considered for a new Sustainable Products legislative Initiative is the development of digital ’product passport’ for consumer products.  

We welcome this initiative and propose the inclusion of a list of materials and substances present in the product, and in which quantities these occur in the products. The ’product passport’ should also include information on presence of hazardous chemicals and their location. Further, a list of legislation and standards that the product complies with, and results of compliance tests against legislations, standards or technical specifications should also be stated in the ’product passport’. Information on sustainability labels and how the product should be recycled and/or handled at the end of life will, if included, help consumers make informed choices and contribute to a Circular Economy and help achieve goals such a Non-Toxic Environment.

The Sustainable Products Policy Initiative is a key part of the Circular Economy Action Plan, and the Commission intends to set product design rules and general product requirements to foster the overall sustainability of products in the EU.  

In this context we stress the importance of:

• Require producers and importers to ensure information on the chemical content of a product is provided on or with a product.
• Ban the use of a substance or substances in a given product, should such substances be found to inhibit product recyclability.
• Require producers and importers to publish information on how they have prioritised materials that are safe and sustainable-by-design, and have substituted chemicals of concern with safer ones whenever possible.

Text: Marie Löf