In October 2020, the European Commission published its chemicals strategy for sustainability towards a toxic-free environment (CSS). This is part of the EU’s zero pollution ambition, which is a key commitment of the European Green Deal. Together with the EU Circular Economy Action Plan and the linked EU Sustainable Products Initiative, this aims to bring about a step change in product safety and sustainability in the EU. Preparations for turning the strategy’s ideas into proportionate and enforceable legislation were ongoing throughout 2021 and will continue for several years. Borealis is taking part in the CEFIC-organised economic analysis of the impacts of the CSS on the European chemical industry and in public consultations on the Sustainable Products Initiative. In addition, the Group is represented in many CEFIC and Plastics Europe working groups dealing with the different aspects of these initiatives, including the ongoing revisions of REACH and the Classification, Labelling and Packaging (CLP) regulation.
Numerous aspects of the CSS have been embedded in Borealis’ ways of working for many years. Borealis is committed to the principles of Responsible Care® and enforces high product stewardship standards, to ensure that its products are used safely at any stage along the value chain.
Borealis’ Product Stewardship department is responsible for ensuring product safety and puts stringent measures in place throughout the entire life cycle. In addition, it gives clear instructions to the organisation to ensure that all products are legally compliant with chemical- and application-related laws in all the countries in which the Group operates and sells.
The Group also ensures that it understands and anticipates consumer and market needs and concerns, as well as the development of legislation concerning chemicals, their applications and the environment, so it can take necessary measures and ensure continued compliance. Borealis also sees the proactive substitution of chemicals of concern as an opportunity to gain market share and be the first to market with an alternative solution.
Making plastics more circular is one of Borealis’ main goals. The Product Stewardship department supports the Group’s work to maintain product safety while using mechanically recycled post-consumer waste. A defined mix of testing and risk assessment, as well as looking at the waste stream and the sorting and cleaning processes, provides the basis of recycled products’ compliance in different application areas.
Group Product Stewardship reports to the Director Health, Safety, Environment and Quality (HSEQ). The team assesses and approves incoming chemicals at Group level and ensures that products comply with general chemical legislation, such as REACH and CLP, as well as application-related legislation, such as food contact or healthcare applications. Product Stewardship activities at national or location level, such as plant-level approvals of raw materials and managing compliance with national chemical laws, are handled by experts who are part of the locations’ HSEQ organisations.
The Product Stewardship Council addresses chemicals of concern in a proactive way. It is chaired by the HSEQ Director and brings together experts from across the Group, including areas such as Product Stewardship, Sustainability, Ethics and Innovation & Technology, as well as all of Borealis’ business sectors and operations. This range of competencies ensures holistic risk assessments that consider market needs, legal and technological requirements and stakeholder views.
The Group’s hazardous chemicals strategy follows the precautionary principle of continuously assessing the risk potential of all substances used in Borealis’ products to identify critical chemicals that need to be replaced by safer alternatives. The Group establishes a list of Substances of Concern (SoC) that is influenced by regulations such as REACH and customer and public perception.
The Product Stewardship Council assesses substances with the highest identified risk, selecting the substances to be evaluated using a proprietary ranking tool. These assessments enable Borealis to identify, mitigate and manage the risks posed by hazardous chemicals.
The Product Stewardship Council also updates the Borealis Banned Substances List of more than 250 substances and substance groups that the Group will not use. In 2021, 28 substances were added to the list, which is published on the Borealis website.
Borealis uses its Portfolio Sustainability Compass to assess the sustainability of its product portfolio. Product Stewardship assesses the Group’s polyolefin products and innovation projects in two categories of the Compass: “Chemical hazard and exposure across the life cycle” and “Global regulatory trends”, and follows up any finding, opportunity or threat.
Borealis’ product safety procedures cover the health, safety and environmental (HSE) aspects of a product throughout its life cycle, from raw material sourcing to its eventual recycling, recovery or disposal.
All new or modified products undergo mandatory HSE assessments and continuous monitoring, to ensure they are suitable for use in the countries where they are sold, and that they comply with all applicable legislation, including REACH. This regulation requires participants in the chemicals value chain to prove the safe use of chemicals. Over the last couple of years, the quality of REACH registration dossiers has been challenged by non-governmental organisations and some EU Member States. CEFIC has therefore established a REACH dossier improvement programme, which Borealis has signed up to and fully supports. The aim is to update all existing dossiers by 2026, with the Group’s progress reported to CEFIC each year. Other relevant legislation and regulations include the Toxic Substances Control Act in the United States, the Globally Harmonised System (GHS) for the classification and labelling of hazardous chemicals, CLP, and, depending on use, any application-related legislation, such as the EU framework regulation on food contact materials.
As a consequence of REACH data generation, more chemicals are being classified as hazardous, which triggers reclassification and labelling requirements for Borealis’ polyolefin products. In 2021, Borealis updated SDSs and label information for 54 products.
Borealis also closely monitors emerging legislation so it can anticipate and take measures to maintain its products’ legal compliance. In line with the REACH principle of “no data equals no market”, this is essential to sell any product worldwide. Borealis therefore incurs the significant costs of registration fees, data creation and external consultancy to ensure compliance.
In 2021, the main focus of these activities was to meet the DUIN deadline in the UK after Brexit and receive PLC exemptions for the REACH-type legislation in South Korea. Forty-seven substances were successfully DUIN-notified by Borealis UK Ltd before 27 October 2021. A further 24 substances for Fertilizers, Melamine and TEN were DUIN-notified by external service providers. PLC exemptions have been granted by the South Korean authorities for all polymers for which Borealis imports more than 1,000 tonnes per year into South Korea. The lower-volume polymers will follow in the coming years, before the respective registration deadlines for the applicable volume bands. In addition, the only high-volume substance subject to the 2021 registration deadline, carbon black, has been successfully registered. To manage the increasing complexity of global labelling requirements, an automatic global label management tool has been rolled out to all relevant EU and North American Borealis production locations.
For Fertilizers, Melamine and TEN, there are two key regulations coming into force in the next two years. These are Regulation (EU) 2019/1009, laying down rules on making EU fertilizing products available on the market, and Regulation (EU) 2019/1148, on the marketing and use of explosives precursors. Implementation projects have been launched and followed up to ensure product compliance and explore potential opportunities.
Borealis’ activities regarding the circular economy and exploring sustainable feedstock result in new product safety and compliance aspects to consider and solve. Both existing and planned legal frameworks, for example, following the EU Commission’s Green Deal, ask industry and brand owners to use post-consumer recycled (PCR) materials for their products. The Product Stewardship team is providing support by generating an overview of applicable legislation and available industry standards to produce a risk assessment and analytical testing strategy to be able to confirm compliance and the suitability of Borealis’ Circular Economy Solutions portfolio.
Moving from fossil to renewable feedstock is another important aspect of the Group’s sustainability journey. Using this type of feedstock from animal and agricultural waste, however, raises other product safety challenges that needed to be tackled. After a thorough analysis of the related aspects, the messages on Kosher, Halal, animal origin, genetically modified organisms and vegan status have been revised in the statement on raw material origin for the PO products concerned.
Before they are approved for use, all incoming chemicals used in Borealis’ products are assessed using a thorough incoming material process. Group Product Stewardship performs an initial assessment to ensure legal compliance. Product Safety teams in the countries where Borealis operates then perform additional assessments at each plant, to ensure the chemical meets plant-specific requirements and complies with national or community related legislation. The raw material approval package must contain a signed specification, up-to-date SDSs and all relevant information as laid down in the Borealis Raw Material Questionnaire. The approval package needs to be reviewed every three years. In 2021, following requests from suppliers, the new component material category was assigned for all fertilizer raw materials, according to the new fertilizer regulation. Once materials are approved for purchase, they are subject to Borealis’ quality control to ensure they continue to comply with the agreed material properties.
All materials are documented based on Borealis’ knowledge of the exact composition of the raw material and on detailed information about the material’s hazardous constituents. Proper documentation of the raw materials used is a key element of high-quality Borealis product compliance statements, such as SDSs, application-related statements (such as medical use, food contact and drinking water) and other statements, such as on raw materials’ origin.
Borealis also regularly audits its raw material suppliers for compliance with, for example, their legal and hygiene requirements. The Group requires its suppliers to provide documentation for each raw material and to keep it up to date, including the information required by national chemical inventory control laws, the CLP and REACH. This enables Borealis to issue the respective SDSs for its customers. In addition, Borealis’ production sites are subject to frequent external audits.
Microplastics are found in the environment, our nutrition and the human body. Once in the environment, microplastics do not biodegrade and tend to accumulate, unless they are specifically designed to biodegrade in the open environment or salt water. They are often mistaken for food by birds and turtles, and swallowed particles can lead to injuries or starvation.
In its 2019 report on microplastics in drinking water, the WHO concluded that “no reliable scientific information available today suggests a potential human health risk associated with exposure to microplastics”.
However, research on microplastics is complex and in its infancy and a lot remains uncertain. Scientists agree that today’s evidence provides sufficient grounds for genuine concern. SAPEA concludes that, if microplastic pollution is left unchecked, business-as-usual would lead to concentration thresholds being exceeded in the near future and the occurrence of widespread risk within a century.
As it is not possible to completely remove microplastics once they are in the environment, the priority is to prevent plastics leaking into the environment in the first place. To develop effective and efficient solutions, more sound scientific knowledge is needed about the source, fate, persistence and effect of microplastics. Borealis has therefore installed a cross-functional Microplastics Issue Team, which closely follows scientific knowledge generation, evaluates emerging studies and collaborates with value chain partners and industry associations in the development of new studies.
For example, Borealis actively contributes to the EU-funded CORNET (Collective Research Networking) project, Microplastics@Food, which is investigating the presence of microplastics in food. Initiated by the Österreichisches Forschungsinstitut für Chemie und Technik (OFI) in Vienna, the project is run by a consortium organised by the Food Cluster of Lower Austria, along with several industrial and academic partners.
In 2021, Borealis, MAM Baby and OFI Vienna initiated a study on microplastics released from baby bottles. The conclusion was that the microparticles detected in the bottle were a result of the production process and after washing and cleaning these could be removed completely.
Borealis also proactively engages in working groups, along with Plastics Europe and CEFIC. The Group’s experts contribute to CEFIC’s Microplastics Issue Team, as well as to Plastics Europe’s Microplastics Strategic Group, Operation Clean Sweep Taskforce and Microplastics Science Group.
Product Stewardship has added instructions on how to avoid accidental release to the environment to all product safety documentation, such as SDSs and Product Safety Information Sheets (PSISs) issued from October 2020 onwards.
Borealis communicates with its stakeholders on Product Safety through a wide range of channels. The Borealis website allows anyone to find information about the Borealis Banned Substances List. The website also includes examples of successful substitutions of hazardous chemicals and some position statements regarding “hot topics”. Borealis’ Polyolefin customers can download SDSs, PSISs and other general or application-related compliance statements from the Borealis website or the MyBorealis customer portal.
When product modifications may influence customers’ safety or require additional testing of finished articles, Borealis informs customers or authorities in due time before it makes the modifications. Borealis also informs customers in advance when legislative changes have consequences for them. For example, customer letters were sent out in October 2021 to inform them about classification and labelling changes effective from March 2022.
In addition, Borealis offers training and education to customers. Sharing Borealis’ expert product safety knowledge with value chain partners makes an important contribution to helping customers continuously meet the highest product safety and quality standards.
Collaboration in the value chain is also instrumental to mechanical recycling. Together with customers, Borealis is defining the boundaries to guarantee the safety of PCR plastics in different applications, as no established standards are available yet.
In Fertilizers, Borealis offers education and awareness activities for farmers. This informs them about proper use of mineral fertilizers and how to avoid pollution of groundwater or soil.
Borealis actively participates in industry associations and standardisation groups to stay at the forefront of regulatory and public requirements. The Group is an active member of the Product Stewardship teams at CEFIC, Plastics Europe and related national organisations. The Group works closely with its own experts, customers and suppliers, and engages in experience exchange at REACH conferences and other activities. As a member of Fertilizers Europe and related national associations, Borealis takes part in discussions on draft regulations and their applications. In 2021, the relevant topics included details of the new fertilizer regulation and its guidance on labelling.
During 2021, the Group took part in an information exchange with the Federal Institute for Occupational Safety and Health in Germany (BAuA), after participating in a public consultation on the Regulatory Management Option Analysis for Melamine. The aim of the outreach was to provide information on the safety of the main use of melamine as a monomer for resin production and that this use should not be restricted or banned if melamine is identified to be a substance of very high concern (SVHC).
The Group’s product stewardship objectives are to:
