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The Potential Impact of the European Green Deal's CSS on Indonesia's Essential Oils Industry

Indonesia's essential oils industry faces potential challenges due to the European Green Deal's Chemical Strategy on Sustainability (CSS). The CSS aims to ensure the safe and sustainable use of chemicals in the European Union (EU) through stricter regulations and hazard-based assessments. This article will go into the implications of the CSS on Indonesia's essential oils industry and suggests measures to prepare for these changes.

Hazard Determination of Individual Constituents

Under the CSS, the regulation of essential oils (EOs) would be based on the hazard determination of individual constituents rather than evaluating the toxicology of the substance as a whole. This approach may lead to bans on certain essential oils that contain constituents considered hazardous under the new regulations. For instance, essential oils containing methyl eugenol or gamma-terpinene may face restrictions even if the full oil itself does not pose a toxicology concern.

To address this challenge, Indonesian essential oil producers should conduct in-depth research and analysis of their products' constituents. By identifying and quantifying potentially hazardous components, producers can develop strategies to mitigate risks. Additionally, exploring alternative extraction methods or partnering with research institutions can aid in identifying substitutes or modifying the composition of essential oils to comply with EU regulations.

Creation of New Hazard Classes

The CSS introduces five new hazard classes within the Classification, Labelling, and Packaging (CLP) regulation. These new hazard classes, such as endocrine disruptors (ED) and substances that are persistent, bioaccumulative, and toxic (PBT), may impact several essential oils and natural complex substances (NCSs). The classification of EOs and NCSs as substances of very high concern (SVHCs) may result in their potential ban due to environmental and health concerns.

To navigate these new hazard classes, Indonesian essential oil producers should closely monitor updates to the CLP regulation and identify the specific implications for their products. Conducting comprehensive risk assessments and collaborating with regulatory bodies can help ensure compliance with the new classification criteria. Producers can also consider diversifying their product portfolio to include alternative natural ingredients that align with the new hazard classes.

Shift from Risk-based to Hazard-based Assessments

The CSS proposes a shift from risk-based safety assessments to hazard-based assessments. This means that if any constituent within an essential oil is deemed hazardous, the entire oil could be classified as hazardous. The "safe for its intended use" concept, widely accepted for flavor materials, may no longer be recognized. Consequently, there is a potential for restrictions or bans on the use of essential oils in consumer end-use products within the EU.

To adapt to this change, Indonesian essential oil producers should emphasize comprehensive risk assessments that consider both hazard and exposure levels. Collaborating with industry associations and research institutions can support the development of scientific data to demonstrate the safe use of essential oils. Engaging in advocacy efforts to promote the benefits of essential oils and their intended uses can also help mitigate the impact of hazard-based assessments.

REACH Dossier Requirements and Small Enterprises:

The CSS implies an increase in REACH dossier requirements, particularly for small and medium-sized enterprises (SMEs) dealing with small volume materials. SMEs in the essential oils industry may face significant challenges due to the additional costs associated with meeting the new documentation and testing requirements.

To overcome these hurdles, Indonesian SMEs should consider forming alliances and partnerships to share resources and expertise. Collaborating with larger enterprises or industry associations can help SMEs navigate the increased requirements and share the costs of compliance. Seeking support from government bodies and exploring funding opportunities for SMEs can further alleviate the financial burden.

The European Green Deal's Chemical Strategy on Sustainability poses potential challenges for Indonesia's essential oils industry. By understanding the specific implications of hazard-based assessments, new hazard classes, and increased REACH dossier requirements, Indonesian essential oil producers can proactively prepare for the changes. Collaboration with industry associations, research institutions, and regulatory bodies will be crucial in developing sustainable alternatives, conducting comprehensive risk assessments, and advocating for the industry's interests. By embracing these proactive measures, Indonesia's essential oils industry can adapt to the evolving regulatory landscape and continue to thrive in the EU market.

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-EU Strategy & Policy - Green Deal

-EU Chemicals Strategy for Sustainability Towards a Toxic-Free Environment

-EU REACH Regulation:

-EU CLP Regulation:

-European Green Deal poses an existential threat to Essential Oils, IFEATWORLD Summer 2023


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