A ROADMAP NOWHERE?

The report argues that the EU's Restrictions Roadmap is failing to meet its ambition of creating a 'non-toxic environment' due to narrow chemical grouping, excessive industry derogations, and systemic regulatory delays. While the roadmap provides a list of priorities, the authors find that most current restriction initiatives are too limited in scope to effectively tackle the risks of hazardous substances like bisphenols and PFAS.

• The Restrictions Roadmap has largely failed to meet its objective of implementing broader restrictions through the grouping of substances and addressing a wide range of uses.
• Most restriction proposals target only a small fraction of problematic chemical groups, which perpetuates 'regrettable substitution' where one banned chemical is replaced by another unregulated but equally harmful substance from the same family.
• The use of derogations and exemptions is common, often including non-critical uses, which undermines the goal of banning all non-essential uses of harmful chemicals.
• Regulatory processes are plagued by illegal delays, with legal deadlines for ECHA opinions and European Commission decisions being frequently breached.
• The restriction proposal for bisphenols is considered highly ineffective because it only covers five substances out of 148 known hazardous bisphenols and exempts the primary uses in polycarbonates and resins.
• Regulatory action on PFAS has historically focused on niche or already phased-out substances, though the 'universal PFAS restriction' proposal is noted as a promising exception due to its broad scope.
• The burden of proof for restricting chemicals rests heavily on authorities rather than industry, which slows down the process as companies often withhold essential data.
• The roadmap lacks sufficient transparency regarding the expected year of entry into force for restrictions and the specific reasons for regulatory delays.

APA

Duguy, H., & Romano, D. (2023). A ROADMAP NOWHERE? ClientEarth. https://www.clientearth.org/media/1qymvrcu/roadmaptonowhere.pdf

Chicago

Duguy, Helene, and Dolores Romano. A ROADMAP NOWHERE? ClientEarth, 2023. https://www.clientearth.org/media/1qymvrcu/roadmaptonowhere.pdf.

Wikipedia

{{cite report |last1=Duguy |first1=Helene |last2=Romano |first2=Dolores |title=A ROADMAP NOWHERE? |publisher=ClientEarth |date=25 April 2023 |url=https://www.clientearth.org/media/1qymvrcu/roadmaptonowhere.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{duguy2023roadmap, author = {Duguy, Helene and Romano, Dolores}, title = {{A ROADMAP NOWHERE?}}, institution = {ClientEarth}, year = {2023}, month = apr, url = {https://www.clientearth.org/media/1qymvrcu/roadmaptonowhere.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }