Safe and Sustainable by Design

The SSbD framework, developed by the EC-JRC, seeks to revolutionize how the industry approaches the development of new chemicals and materials. Its primary goal is to promote the design and creation of chemicals and materials that are both safe and sustainable across their entire lifecycle. Supporting the European Green Deal and the Chemicals Strategy for Sustainability (CSS), SSbD integrates safety, environmental, and socio-economic criteria into product design and evaluation. This framework seeks to minimize harm to human health and the environment while promoting sustainable innovation

Alignment with the Ecodesign for Sustainable Products Regulation (ESPR)

The Ecodesign for Sustainable Products Regulation (ESPR) expands on the principles of traditional ecodesign to include a broader range of sustainability criteria beyond energy efficiency. It emphasizes improving product durability, repairability, upgradability, recyclability, and the responsible use of resources. A critical element of the ESPR is its requirement for the use of sustainable substances or materials, and declaration of those that pose risks to human health and the environment, as well as those that hinder recycling.

This stipulation aligns seamlessly with SSbD’s objectives, as both frameworks highlight that sustainable product design involves a holistic approach that considers not only the materials contained in a product but also the entire lifecycle, including associated processes and their impacts. The ESPR's first delegated act, which specifically addresses, among others, chemicals, underscores that the responsible selection of substances is not optional but essential under EU regulation.

Implications for Product Design and Development Processes

Integrating SSbD with ESPR principles reshapes how product development teams approach design, emphasizing:

1. Holistic Life Cycle Perspective: The SSbD framework advocates for a life cycle assessment (LCA) approach, which aligns with ESPR's mandate for a comprehensive analysis that spans from raw material extraction to end-of-life. While not a mandatory requirement, is a scientifically proven and widely accepted environmental impact assessment methodology. This perspective pushes designers to choose safer, more sustainable chemicals and consider their impact across the entire product life, and not only the usage phase. This implies, that product developers should be aware of those design decisions that imply the usage of substances or chemicals as part of the production process, even if those substances or chemicals will not remain as content in the product.

One example is how poor geometry in an injection moulded plastic component could push the manufacturers to use unmolding agents to avoid the part getting stuck in the tooling.

Another example is related to the E-coating. Solvents, pigments and other substances will remain in the immersion and rising water, that will be treated, and the sludge generated in the process will be disposed of as special residue. However, regulatory agencies typically set permissible discharge limits, recognizing that 100% removal is rarely achievable. Those residuals, accumulated from several industries discharging in the same waste stream, pose additional challenges, so, it is much better to prevent the contamination, even if it is minimal.

2. Substance Transparency and Safety: The ESPR requires detailed disclosure of substances that affect human health, environmental safety, and recyclability. This means that beyond selecting environmentally friendly materials, designers must assess the impact of all substances, including those used in manufacturing processes, such as the previously mentioned examples. Although these may not be classified as hazardous in their acute phase according to toxicological or ecological information found in the Material Safety Data Sheets (MSDS), their long-term effects and the accumulation with other different industrial activities in the same area can pose significant risks that are often overlooked, mainly in terms of community impacts and contribution to the whole industrial system.

3. Comprehensive Safety and Hazard Assessments: SSbD embeds early-stage hazard assessments into the design process, ensuring the selection of raw materials or chemicals minimizes risks. This goes hand in hand with ESPR’s focus on non-toxic materials and sustainable practices.

4. Beyond Material Selection: Achieving true sustainability goes beyond simply selecting 'green' materials. Design teams need to consider auxiliary substances used in manufacturing, such as the ones mentioned above. While some substances may have low or negligible toxicity, they can still hinder recyclability and contaminate waste streams. This can render otherwise recyclable materials non-recyclable once mixed with plastics containing these substances. Additionally, as I have emphasized before, Design for Sustainability encompasses a range of strategies beyond material choices, such as Dematerialization, which focuses on completely eliminating the use of materials or substances.

Strategic Integration for Effective Compliance

To meet the requirements set by the ESPR while following SSbD guidelines, product developers must:

• Ensure Substance Transparency: Provide clear declarations of all substances, including those that may hinder recyclability or pose long-term health risks, promoting sustainable and non-toxic material cycles.
• Adopt In-depth Reviews: Consider not just the immediate hazards noted in MSDS, but also the potential cumulative and long-term effects of all substances involved. A comprehensive life cycle and systemic perspective is essential to understand how these substances interact with those from other products or industries. This shifts design from being "user-centric" to "ecosystem-centric," where the impact extends beyond the product’s value stream. It requires factoring in often-overlooked stakeholders, such as local communities, surrounding environmental areas, and waste managers who handle diverse waste streams from various industries. The full supply chain, its own stakeholders and its own supply chain should be, of course, included in this approach. These groups encounter the substances and chemicals just as much as assembly operators or end users of the product.
• Integrate Process Considerations: Include evaluations of substances used in manufacturing processes that are linked to design, to anticipate and mitigate potential environmental and health impacts.
• Balances Performance and Safety: Considers both the functional role of substances (e.g., process aids like unmolding agents) and their environmental and health implications, supporting safer and more sustainable innovation.
• Iterative Design and Redesign: To adhere to both SSbD and ESPR requirements, product development teams must adopt iterative design processes. This allows for continuous improvements in sustainability performance, ensuring that new products meet or exceed regulatory standards

Wrapping up:

The ESPR's binding nature across EU member states mandates that product designs adhere to stringent safety and sustainability criteria, requiring a declaration of all substances that could impact recyclability and health. While the SSbD framework is voluntary, and it offers companies a roadmap to embed these practices into their product development, supporting smoother regulatory alignment and fostering a proactive approach to innovation

By merging SSbD with ESPR practices, product development becomes a robust process that emphasizes full lifecycle safety, substance transparency, and environmental stewardship. This integrated approach ensures compliance, promotes innovation, and contributes to a circular economy where sustainability and safety are inherent from the initial design phase.

How can I help you?

While I may not be a legal expert, staying informed about relevant regulations and standards is critical to my focus on sustainable product innovation. This knowledge allows me to support and guide teams in designing products that meet current sustainability requirements and go beyond compliance to create long-lasting positive impacts.

I invite you to connect and learn more about how we can collaborate to drive sustainability in your product development processes. Click the banner below to connect, and let's start this important conversation.