For goals and planned key actions for 2024 and beyond, please refer to the full Combined Annual Report 2023.
Borealis is committed to the principles of Responsible Care®, which includes ensuring its products are safe. The Product Stewardship department is responsible for product safety throughout a product’s life cycle and gives clear instructions to the organization, 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 (PSISs), to provide guidance on the safe use and disposal of its products, with regard to human health and the environment.
The Group strives to anticipate and understand consumer and market needs and concerns about chemical safety. It also closely follows developing legislation concerning chemicals, their applications and the environment, so it can take necessary measures to ensure safe use and continued compliance. Borealis also sees an opportunity to gain market share by proactively substituting chemicals of concern, thereby adding value for customers and ensuring their products’ continued compliance and sustainability.
The Product Stewardship Council proactively addresses chemicals of concern. It is chaired by the Vice President Health, Safety, Environment and Quality (HSEQ) and brings together experts from across the Group, including Product Stewardship, Sustainability, Ethics and Innovation & Technology, as well as all of Borealis’ business sectors and operations. This range of competencies ensures Borealis conducts holistic risk assessments that consider market needs, legal and technological requirements and stakeholder views.
Group Product Stewardship reports to the Vice President HSEQ. The team assesses and approves incoming chemicals at Group level and ensures that products comply with general chemical legislation, such as REACH and the Classification, Labelling and Packaging (CLP) regulation, as well as application-related legislation, such as food contact or healthcare applications.
At national or location level, experts from the locations’ HSEQ organizations handle Product Stewardship activities, such as managing compliance with national chemical laws or plant-level approvals of raw materials.
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 has a list of substances under scrutiny 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. This enables Borealis to identify, mitigate and manage the risks posed by hazardous chemicals. In 2023, the Group analyzed the use of PFAS in its products, processes, maintenance and equipment. Only a very small number of Borealis’ products contain PFAS, namely fluoropolymeric processing aids. For those products, a phase-out plan was defined and followed up.
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 2023, 10 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.
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 the Group’s products are assessed for their HSE impacts and undergo mandatory compliance assessments against chemical and product regulations, including hazard communication via SDSs and hazard labels. Guidance for correct disposal of Borealis’ products is given on the SDSs or PSISs. For Polyolefin products, those documents also include instructions on how to avoid accidental release of plastic pellets to the environment. The Group reviews the product compliance assessments whenever there is a change in the product or legislation, to ensure products remain suitable for use in the countries where they are sold and continue to comply with all applicable legislation. However, in some cases these compliance assessments were performed too late in the change process for the products, when the material was already being produced in the Group’s plants. This learning triggered the integration of the compliance assessment into the product approval workflow. This ensures that from 2024 onwards, when the change is fully implemented, no unassessed product recipe can end up in the production lines.
Borealis’ products comply fully with REACH. This regulation requires participants in the chemicals value chain to prove the safe use of chemicals and to submit the required evidence to the European Chemicals Agency, in a registration dossier. In recent years, non-governmental organizations and some EU Member States have challenged the quality of these registration dossiers. Cefic has therefore established a REACH dossier improvement program, which Borealis has signed up to and fully supports. The aim of the program is to update all existing dossiers by 2026. In addition to updating 25 existing registrations, in 2023 Borealis filed five 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 Harmonized 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.
In the EU, Switzerland, China, Japan and the Mercosur region, new legislation has revised the approval schemes for plastics that come into contact with food. During 2023, Borealis assessed and implemented the new requirements across its food contact product portfolio, by providing updated “Declaration of Compliance with Food Contact Regulations” documents to customers.
Borealis’ other activities in 2023 included:
In 2023, Borealis identified no incidents of non-compliance with regulations and/or voluntary codes concerning the health and safety impacts of products and services, or product and service information and labeling.
All incoming chemicals used in Borealis’ products are assessed using a thorough incoming material process, before they are approved for use. 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 the information in the Borealis Raw Material Questionnaire. The approval package is reviewed at least every three years. Following an internal audit finding that the review date of several raw materials was overdue and supplier documents had not been updated, corrective actions were implemented in 2023. As well as better allocation of resources in Product Stewardship, special focus has been given to educate the raw material business responsible and to develop a report dashboard to help prioritization of the raw materials that are actively sourced. 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 second-party audits (e.g. customer audits) and third-party audits (e.g. ISO certification 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 when 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 post-consumer recycled (PCR) materials for their products. The Product Stewardship team is generating an overview of legislation and industry standards, to produce a risk assessment and analytical testing strategy that can confirm compliance and the suitability of Borealis’ Circular Economy Solutions portfolio.
During 2023, new ways of working regarding approval of novel recyclate feedstock sources were implemented to support key growth areas including the acquisitions of Rialti S.p.A. and Integra. A categorization system for different types of feedstock was developed that defines the required safety documentation and analytical test results for each EU feedstock, thereby streamlining the procurement process. In 2023, Borealis focused on strategies to enable the use of PCR material for more sensitive applications. For example, Product Stewardship supported a business project looking into closed loop recycling opportunities for automotive applications. The current draft of the EU’s revised End of Life Vehicles Directive requires a step-change increase in PCR plastic content in cars. Borealis’ project assessed the risk of potential waste streams being contaminated with substances of concern, with a special focus on the Global Automotive Declarable Substance List. A set of analytical tests were proposed to mitigate those risks. The Group is also taking part in an industry consortium to look at cosmetic packaging applications (see Sharing Product Safety Knowledge Across the Value Chain below).
The Lower Olefins and Aromatics (LOA) REACH consortium brings together companies who manufacture or import these products, to support them with their REACH registrations. To assist Borealis’ chemical recycling ambitions, Product Stewardship pushed for the consortium’s decision that alternative feedstocks can be covered by the existing standard (fossil) REACH registrations of LOA substances, if they meet the defined sameness criteria.
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 Policy by European Academies concludes that, if microplastic pollution is left unchecked, business-as-usual would lead to concentration thresholds being exceeded in the near future and that widespread risks would occur 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 set up 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 developing new studies.
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.
Furthermore, Product Stewardship has added instructions on how to avoid accidental release to the environment to all product safety documentation, such as SDSs and PSISs, issued from October 2020 onwards.
In October 2020, the European Commission published its “Chemicals Strategy for Sustainability 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 have been ongoing since 2021 and will continue for several years.
Cefic has organized an economic analysis of the CSS’s impact on the European chemical industry. During 2023, Borealis has continued to take part in this work, particularly in two studies on PFAS. The first study assessed the economic impact of a proposed restriction on PFAS and the second study considered the use of PFAS materials in industrial equipment. Cefic submitted both studies to the public consultation on the restriction. In addition, Borealis 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 CLP regulation. An internal impact assessment highlighted the importance of the Product Stewardship Council and the need for extra resources to handle the substitution of an increasing number of substances of concern.
Borealis communicates with its stakeholders on product safety through a wide range of channels and thereby manages its positive impacts. 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.
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. For example, Borealis is an active member of the Cosmetics, Packaging and Toxicology (CosPaTox) consortium and project, which is looking into the development of safety guidelines for using PCR materials in cosmetic packaging.
Borealis actively participates in industry associations and standardization groups to stay at the forefront of regulatory and public requirements. The Group is also an active member of the Product Stewardship teams at Cefic, Plastics Europe and related national organizations. The Group works closely with its own experts, customers and suppliers, and engages in experience exchange at REACH conferences and other activities.
The Group’s product stewardship objectives are to:
Beyond 2024, Borealis will prepare to implement elements of the EU’s CSS, such as the new hazard classes, microplastic labeling and reporting that will be required by 2026, as well as new requirements from the revised REACH regulation. Furthermore, Borealis will improve existing and implement new IT tools, to improve efficiency and data quality and reduce the risk of human error by centralizing data storage, thereby lowering the risk of product safety incidents and non-compliance.
