Borealis’ Product Stewardship department is responsible for ensuring product safety throughout a product’s entire life cycle. The Product Stewardship team gives clear instructions to the organisation, to ensure that all products comply with chemical- and application-related laws in all the countries in which the Group operates and sells. The Group also publishes Safety Data Sheets (SDSs) and product safety information sheets, to provide guidance on the safe use and disposal of Borealis’ products, with regards to human health and the environment.
The Group ensures that it understands and anticipates consumer and market needs and concerns about chemical safety, as well as the development of legislation concerning chemicals, their applications and the environment, so it can take necessary measures and ensure continued compliance.
In addition to ensuring legal compliance and the health and safety aspects of its products along the entire value chain, Borealis sees the proactive substitution of chemicals of concern as an opportunity to gain market share. This will bring value to the Group’s customers and ensure their products’ continued compliance and sustainability.
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 Classification, Labelling and Packaging (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 Director HSEQ 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.
In October 2020, the European Commission published its Chemicals Strategy for Sustainability (CSS) towards a toxic-free environment. 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 2022 and will continue for several years.
Borealis has continued to participate in the Cefic-organised economic analysis of the impacts of the CSS on the European chemical industry. In addition, the Group is represented in many Cefic and Plastics Europe working groups dealing with 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 every stage along the value chain.
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 2022, 14 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 Polyolefin 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.
In Fertilizers, Melamine and TEN, continuous regulatory monitoring of the business’s substances enables it to assess the potential risk of additional legal action. Melamine has been identified as a Substance of Very High Concern (SVHC) and will be added to the candidate list of SVHC for Authorisation and possibly to Annex XIV of REACH, which means an authorisation would be needed for further usage.
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 of the Group’s products are assessed for their health and safety impacts, as well as compliance with chemical and product compliance regulations, including hazard communication via SDSs and hazard labels. All products undergo mandatory compliance assessments that are reviewed whenever there is a change in the product or the applicable legislation, to ensure they are suitable for use in the countries where they are sold, and that they comply with all applicable legislation. Guidance for correct disposal is given on the SDSs or Product Safety Information Sheets of Borealis products. For Polyolefin products, those documents also include instructions on how to avoid accidental release of plastic pellets to the environment.
Borealis’ products are in full compliance with REACH. This regulation requires participants in the chemicals value chain to prove the safe use of chemicals. In recent 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 of the programme is to update all existing dossiers by 2026. In addition to improving the Group’s existing registrations, in 2022 Borealis filed four additional registrations to allow the import of new raw materials to its EU production plants.
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.
One of the main goals of REACH was to generate more data to better understand the potential hazards and control the risks of the chemicals that are used. Borealis is actively following its suppliers’ SDSs and the harmonised classification process, to ensure it always has accurate and up-to-date SDS and label information for its products.
The PO product portfolio that Borealis sells to Turkish customers contains about 70 substances that require a Turkey REACH registration. In 2022, Borealis put considerable effort into preparing for the 2023 registration deadline in Turkey.
In Fertilizers, Melamine and TEN, the main focus was to prepare the inquiries under UK REACH for the substances for which the business wants to be lead registrant. Creating a Substance Information Exchange Forum is more difficult, as the UK Government may delay the registration deadline by three years.
Fertilizers, Melamine and TEN has also worked hard to ensure it complied on time with Regulation (EU) 2019/1009, which lays down rules on making fertilizing products available on the EU market. While the regulation came into force on 16 July 2022, amendments are still ongoing and it will take time to create notified bodies, which are mandatory to sell solid fertilizers based on ammonium nitrate with high nitrogen content. The business has launched implementation projects and followed up to ensure product compliance and explore potential opportunities.
No incidents of non-compliance with regulation and/or voluntary codes concerning the health and safety impacts of products and services were identified. There were also no incidents identified of non-compliance with regulations and/or voluntary codes concerning product and service information and labelling.
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 is reviewed every three years.
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.
Making plastics circular is one of Borealis’ main goals. The Product Stewardship department plays a key role by supporting the Group’s work to maintain product safety while using mechanically recycled post-consumer waste, which by its nature does not have a defined and homogenous chemical composition. Both existing and planned legal frameworks, for example, following the EU Commission’s Green Deal, ask industry and brand owners to use postconsumer 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 that can confirm compliance and the suitability of Borealis’ Circular Economy Solutions portfolio. In 2022, all Borealis, mtm and Ecoplast mechanically recycled products underwent analytical testing to support the confirmations in Borealis’ compliance statements. These documents were harmonised and published during 2022 and proved highly valuable to the Group’s customers.
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 much remains uncertain. Scientists agree that today’s evidence provides sufficient grounds for genuine concern. Science Advice for European Policy (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 therefore has 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.
Borealis 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.
Furthermore, 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 with 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. Borealis is, for example, an active member of the CosPaTox consortium and project, looking into the development of safety guidelines for the safe use of post-consumer plastic recyclates in cosmetic packaging.
In Fertilizers, Melamine and TEN, 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, using tools such as NutriGuide™, NutriZones™ and N-Pilot™.
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 2022, the relevant topics included details of the new fertilizer regulation. During 2022, the Group took part in advocacy activities for melamine. The EU melamine producers together with the Downstream User Sector organisations (EPF and Formacare) coordinated their response to the upcoming public consultation on the identification of melamine as a substance of very high concern.
The Group’s product stewardship objectives are to:
