Ongoing development of the EU’s ‘critical chemicals’ criteria is raising questions over whether substances vital to strategic value chains should still qualify if they are also considered hazardous – an issue that could shape policy backing, regulatory scrutiny and substitution across sectors.
The European Commission-led Critical Chemicals Alliance (CCA) aims to identify molecules and production sites essential to strengthening the EU’s resilience in strategic sectors such as clean technologies, defence and health. The effort is driven by the EU’s competitiveness agenda.
A ‘critical’ label could signal long-term policy support, while exclusion or overlap with restrictions could influence substitution plans, technology development and market access.
Some stakeholders say the way the bloc defines ‘critical’ will determine whether it accelerates the shift to safer, more sustainable chemistry or risks entrenching hazardous substances.
The Commission says the exercise is separate from chemical risk management. In its view, hazardous substances may still be used in critical industrial applications under controlled conditions, so the aim is not to identify dangerous chemicals, but to assess strategic importance from an industrial policy perspective.
It adds that the initiative should help target policy support as the sector faces high production costs, trade distortions and volatile demand, while leaving existing chemicals rules in place and addressing substitution through separate frameworks.
Strategic importance
Cefic, a participating organisation in the alliance, says a substance can, in principle, be both hazardous and critical, and argues that this distinction should be central to how the Commission approaches the issue.
The industry body says a hazard classification under the EU’s CLP Regulation reflects a substance’s intrinsic properties but does not, on its own, determine risk, which depends on how the substance is used and whether that use can be controlled safely.
On that basis, it says the identification of critical chemicals should be proportionate and evidence-based, rather than assuming hazardous substances cannot also be strategically important. Cefic describes the exercise as analytical and focused on resilience, aimed at mapping supply chain dependencies without pre-empting regulatory decisions.
Beyond resilience
Joel Tickner of the University of Massachusetts Lowell, who is participating in the process, says ‘critical chemicals’ should reflect not just functional importance, but also Europe’s competitive strengths and long-term sustainability goals.
In his view, priority should go to substances that support innovation, regional autonomy and cleaner industrial development, rather than to incumbent chemistries that compete primarily on cost.
Professor Tickner says hazard has so far been largely absent from discussions and warns that the talks risk using supply chain concerns to protect vulnerable existing chemistries instead of accelerating the development of safer and more sustainable alternatives, including those based on regional renewable feedstocks.
Without a framework balancing economic, safety and sustainability criteria, he said, the EU could lock itself into uncompetitive, low-value production models.
Representing the other end of the sector, the Downstream Users of Chemicals Co-ordination Group (DUCC) said it could not comment on whether a substance can be both critical and hazardous, as its engagement in the alliance is mainly focused on demand-side aspects and market uptake.
But it said the alliance’s work should align with the Commission’s goals on simplification and competitiveness, especially for SMEs, and be backed by impact assessments to ensure proposals are feasible and proportionate across the value chain.
Next steps
The alliance’s first major deliverables – including the methodology and criteria for identifying critical chemicals and production sites – are expected to be presented to its General Assembly in the autumn for discussion and approval, before being fed into recommendations to the Commission.