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NGO Input to a Possible High-Level Declaration of the Fifth International Conference on Chemicals Management

NGO Input to a Possible High-Level Declaration of the Fifth International Conference on Chemicals Management

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A group of NGOs provided input to a Possible High-Level Declaration of the Fifth International Conference on Chemicals Management (ICCM5) to be held on the 25 – 29 September 2023, in Bonn, Germany.

The following structure of the ICCM5 HLD is suggested:

1. Alignment of the chemicals and waste clusters with other multilateral agreements of relevance to provide solutions to the three converging crises of climate change, loss of biodiversity and pollution 

Management of chemicals and waste is a cross-cutting issue. It should be viewed as key for solving several elements of the planetary crisis, e.g. biodiversity loss and resource depletion because toxicity considerations now limit the efficient use of already manufactured materials and products and is an obstacle to circularity and ending plastic pollution and climate change. In addition, chemicals and waste management is critical in addressing other global emergencies, such as health at a general level, food and energy security.  All of these would be crucial to highlight in the High-Level Declaration to send a strong and clear message to the world leaders that the topic of chemicals and waste must be significantly raised on the policy agenda at all levels.

2. Recognition of the gaps between the high and low to middle-income countries and their capacity to detect and analyze hazardous chemicals and the responsibility of producing and exporting countries

Insufficient legislation on chemicals and waste and its poor enforcement in low to middle-income countries, as well as the absence of harmonized standards for chemicals of global concern not covered by existing multi-lateral agreements, leads to unavoidable pollution and irreversible damage to people’s health and the environment. At the same time, producing and exporting countries have a higher responsibility and accountability for damage and loss caused by industry in their countries. Exporting chemicals, which are banned in producing countries, to countries of the global South has to be stopped.

3. Acknowledgement of issues of concern (IoCs)

All Issues of concern (IoCs) should be acknowledged for their relevance to the Agenda 2030, and their function to provide an international forum to discuss them should be noted. However, it is essential to highlight that progress so far is mainly limited to information gathering, and only some concrete risk elimination or risk reduction measures have been undertaken. Even lead in paint -the IoC, which has received the most attention and funding to date – remains an issue in too many countries, mainly with developing and transition economies. The HLD must stress the urgent need to see substantial progress in the work with Issues of Concern (IoCs), which requires stepping up the IoC work considerably, primarily through higher ambition level in the voluntary actions under the SAICM successor, but not excluding through elevation of obligations outside its frames if progress is still insufficient in relation to the suggested criteria.

4.   Globally harmonized transparency and traceability system

The HLD must admit that while for chemical elements and mixtures, the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) provides means for disclosing the identity of chemicals and hazard communication that supports informed decision-making, a corresponding harmonized system for disclosing chemicals in manufactured solid materials and products at the global level is missing [9]. This is a considerable obstacle to the realization of sound management of chemicals and waste in the context of material life cycles. The lack of information on chemicals in solid manufactured materials and products undermines the safety of the circular economy and its ability to address many SDG targets. A circular economy can be safe to human health and the environment only if all stakeholders along the value chains can make informed decisions based on information about the chemical composition of manufactured materials and products. Correct decisions can then be made for the design and manufacturing of products, including substitutions of problematic chemicals. Importers, retailers, institutions involved in public procurements, and consumers can make informed decisions and handle waste correctly. Waste dealers, sorters and recyclers can make correct decisions to provide safe secondary raw materials. A toxic-free circular economy must build on transparency of information on toxic chemicals and their traceability in individual materials and products within the product lifecycles. It can reduce the need for new virgin raw materials and associated needs for energy, water and processing/refining chemicals in connection with extraction/production, refining of materials and manufacturing of products. Thereby, it could reduce climate impact, chemical pollution, water stress and other negative impacts on the ecosystems, and at the same time, address the waste issue. In summary, toxic-free circular economy would support fulfilling several key targets of the Sustainable Development Goals.

5. Highlighting the importance of synergy between the Beyond 2020 Chemicals Strategy and other existing and future MEAs.

Recognizing synergies between the chemicals and waste sector and other multilateral agreements, standards and activities in various areas such as health, agriculture, labour, biodiversity, climate and human rights is essential to promote sustainable development and ensure the well-being of people and the environment. For example, recognizing synergies between the chemicals and waste sector and agreements and standards related to health and agriculture can contribute to the safe management and use of chemicals, minimizing negative environmental impacts, safeguarding food safety, and reducing risks to human health and well-being. Existing chemical treaties provide limited coverage of the regulatory aspects related to the entire life cycle management of chemicals, making it challenging to effectively implement measures for the sound management of chemicals. Therefore, the synergy between the Beyond 2020 Chemicals Strategy and existing MEAs must be prioritized as it establishes a framework that functions as an umbrella mechanism.

6.   Integrating the principles of green chemistry and non-chemical alternatives

The HLD should highlight the importance of integrating the principles of green chemistry and encourage the use of non-chemical alternatives in the Beyond 2020 instrument. It should promote establishing regulations that encourage the use of safe alternatives, providing incentives for research and development of safe technologies, and implementing green public procurement policies to create demand for environmentally friendly products.

7.     Ensuring public engagement

Ensuring public engagement requires an inclusive occupational safety and environmental health approach. This can lead to encouraging public participation.

Engaging the public in the sound management of chemicals and wastes, including Indigenous and minority peoples, vulnerable groups and people at risk, is critical to support effective and sustainable community-based solutions and foster their ownership, accountability, and shared responsibility in addressing chemicals and waste issues. It enables the development of policies and practices that meet the needs and aspirations of various groups, including the most vulnerable, such as women, workers, and Indigenous Peoples, and consider their knowledge, experience, and needs while protecting human health, the environment and sustainable development.

8.     Promote gender equality and justice

Ensuring women’s equal and meaningful participation and representation in decision-making processes related to chemicals and waste management is crucial. The HLD must highlight the importance of involving women’s organizations, Indigenous Peoples, Local Communities, and gender experts in chemical policy development, planning, and implementation to address women’s specific needs, priorities, and perspectives, ensuring gender equality and women’s empowerment, access to justice and application of the legal principle of Free Prior and Informed Consent to ensure that local communities have decision making and can protect against polluters on their territories.

9.     Strengthening financial means of implementation

Sustainable financing is a keystone for effective implementation of the Global Plan of Action of the successor to SAICM, so the HLD must give a clear signal of the necessity to not just build on the Integrated Approach to long-term funding of the Chemicals and Waste Agenda, but also incorporate novel approaches to financing, e.g. a “global” fee leveraged from the chemical industry for basic chemicals following the polluter pays principle. The fee would replace the Responsible Care Programme, through which industry now largely controls what they fund, and thus may create situations where commercial interests primarily dictate the allocation of the funds.

10.  Enabling framework for chemicals and waste

The HLD should stress the necessity of an enabling framework for chemicals and waste as a key supportive function to the SAICM successor. The UNGA decision should call all IGOs relevant for chemicals and waste management and health to make the Beyond 2020 framework central to their policies and programmes wherever they involve chemicals and waste.

The full submission is available here:

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Written by Olga Speranskaya

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