Different views appeared on this question. Some actors felt that all relevant information is available to safely substitute BPA, most actors however indicate that crucial information is still missing. The following may still be needed:
- A clear and preferably stable definition on what is meant with safe and sustainable. What criteria should we look at to indicate that an alternative is safe and sustainable? With respect to ‘safe’, actors seem to have some ideas based on regulatory requirements, for ‘sustainable’ it is somewhat more vague. Authorities would be the main actor to clarify these terms.
- Better information on hazard and risk on the alternatives to be able to select the right alternative and to ensure safe use. It may also be helpful according to some actors if authorities indicate what alternatives are ‘safe’ and push these to stimulate safe substitution. There are some challenges indicated in this respect.
- As a general principle, industry is responsible for the substitution. The role of government in substitution is about informing, warning, enforcing and supporting when necessary/relevant.
- REACH system with tonnage bands may hamper the generation of relevant hazard information on alternatives. When developing an alternative, it is often manufactured at low tonnages and consequently limited hazard testing is required by the REACH regulation for low tonnage band. Based on this limited testing there may not (yet) be an indication for a concern. While increasing production, a registrant could move to a higher tonnage band resulting in an increase in hazard information generation. This additional information could indicate risk issues that were not identified earlier. This can entail high business risk in developing (regrettable) alternatives.
- Consequently, there is a need for improved cheap and reliable screening tests for alternatives.
- Specifically for endocrine disruptors, there is a need for explicit criteria (in the context of REACH) and consequent testing requirements.
- How to compare various hazard effects of BPA and its alternatives is also perceived as an essential issue.
- Need for information on costs and technical performance of alternatives. Users need clear information on the added value of alternatives e.g. to motivate the adoption of safer alternatives despite the higher price. The higher price of alternatives appears to be an issue when marketing them.
- Better supply chain communication to make sure all actors in the supply chain know how to handle the substance/product safely. The possibility to improve communication by the suppliers of the substances used in thermal paper and by the suppliers of thermal papers was mentioned.
- Sufficient availability of safe alternatives on the market. Avoid the situation of there being a single supplier on the market. Patents represent a constraint in this respect. This point may be a bit outside information/knowledge but still very relevant for effective substitution possibility for the downstream supply chain actors.