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When negotiators convene at the fifth International Conference on Chemicals Management (ICCM5) in Bonn, Germany, in September 2023 to decide on a new global framework for the sustainable management of chemicals and waste, they will consider draft targets, and one of the proposals for implementation of the new framework seeks to encourage select “chemical intensive economic sectors and value chains” to scale-up global action that produces concrete results. One specific draft target calls for the development of sustainable chemical and waste management strategies in chemical intensive sectors and industries across value chains. The negotiations seek to develop a new global framework to replace the Strategic Approach to International Chemicals Management (SAICM) created by ICCM1 in 2006.

At a January 2023 workshop convened in Paris, France, by the proponent of the implementation proposal, the Inter-Organization Programme for the Sound Management of Chemicals (IOMC), textiles was discussed as a candidate sector for implementation. The IOMC plans a further stakeholder consultation from 20-21 June 2023 to flesh out ideas for guidance to support strategies and a possible global programme on advancing chemicals and waste management in economic industry sectors and their value chains.

At a negotiating session held in Bucharest, Romania, in August 2022, the textiles sector was an active participant in the talks: the Zero Discharge of Hazardous Chemicals (ZDHC) – a multi-stakeholder organization comprising over 150 contributors, including leading brands such as Adidas, Nike, and Levi Straus – made statements about the sector’s desire to actively engage in the future framework, and offered proposals for framework elements such as sectoral targets and indicators.

The UN Environment Programme (UNEP) has identified textiles – which encompasses not only apparel and footwear, but also some home furnishings (e.g., carpets, curtains, and upholstery) and “technical textiles” (e.g., medical textiles, geotextiles, seat covers, and protective clothing) – as a high-priority industry sector in shifting to a circular economy. Its importance to economies, natural resource management, gender equality, and sustainable development has been reflected in UNEP’s Medium-Term Strategy, resulting in the development of UNEP’s Textile Flagship Initiative. The Initiative aims to align UNEP’s work across three priorities needed to deliver system change towards sustainability and circularity – shifting consumption patterns, improving practices, and investing in infrastructure. These priorities are reflected in UNEP’s forthcoming report titled, ‘Sustainability and Circularity in the Textile Value Chain: A Global Roadmap.’ One of the impact areas of the project aims to reduce pollution in the environment and its impacts on human health by managing chemicals of concern across the textiles value chain.

This Policy Brief discusses SAICM’s longstanding interest in the textiles sector, the IOMC’s proposal, and how an implementation programme under the successor framework might engage with the industry.

SAICM and its interest in the textiles sector

SAICM grew out of a goal endorsed by the 2002 World Summit on Sustainable Development (WSSD) for the world to use and produce chemicals by 2020 in ways that minimize significant adverse effects on human health and the environment. The WSSD also called for developing “a strategic approach to international chemicals management” by 2005. This led to SAICM’s launch at ICCM1 in 2006 as a flexible, voluntary, non-binding, multi-stakeholder, and multi-sectoral initiative dedicated to promoting collaboration aimed at achieving the 2020 goal.

As originally conceived, SAICM was due to expire when ICCM5 convened in 2020. However, by the time ICCM4 convened in September 2015, it became clear that the 2020 goal would not be achieved in most countries. ICCM4 decided to launch an intersessional process aimed at designing a post-2020 framework or platform for the sound management of both chemicals and waste for consideration by ICCM5 in 2020. Due to delays in negotiations caused by the COVID-19 pandemic, ICCM5 was postponed until September 2023.

SAICM’s interest in the textiles sector as a significant user of chemicals came early, primarily through its Chemicals in Products (CiP) initiative. CiP was designated as an Emerging Policy Issue in 2009, and a CiP Programme was created by ICCM3 in 2012, led by UNEP, with a focus on four priority sectors, one of which was textiles. In the run up to ICCM3, UNEP produced a CiP case study on chemicals in textiles.

SAICM has also produced relevant knowledge products, such as the report and a policy brief on addressing per- and polyfluoroalkyl substances (PFAS) as a chemical class in the textile industry. The report and brief suggest how SAICM might advance the concept of approaching PFAS as a class of chemicals for control purposes, rather than chemical-by-chemical as the Stockholm Convention on Persistent Organic Pollutants (POPs) does, and phase out non-essential uses, the textile sector serving as a test case.

IOMC’s proposal for sectoral implementation programmes under a new global framework

The IOMC is an international coordinating group bringing together nine Participating Organizations to promote sound chemical management worldwide through coordination of policies and activities. Participating Organizations include UNEP, the Food and Agriculture Organization of the UN (FAO), the International Labour Organization (ILO), the UN Development Programme (UNDP), the UN Industrial Development Organization (UNIDO), the UN Institute for Training and Research (UNITAR), the World Health Organization (WHO), the World Bank, and the Organisation for Economic Co-operation and Development (OECD).

In a discussion paper presenting its proposals for an implementation programme under the new global framework, the IOMC suggests encouraging further action “based on industry initiatives that have been initiated voluntarily, resulted from regulatory requirements, or responded to pressure from public interest groups.” It also suggests choosing industry sectors and product value chains whose retailers have already undertaken “frontrunner” initiatives demonstrating commitment and willingness to engage, with a view to strengthening, linking, and expanding such initiatives.

The textiles industry qualifies on all counts. Major brands and retailers form the backbone of ZDHC. They have already developed several chemical restriction lists, management guidance, and standards, and backed certification and labeling schemes. Major brands, retailers, trade associations, and others in the sector have also engaged in the Ellen MacArthur Foundation’s Make Textiles Circular initiative, the Fashion Pact, the Policy Hub, and the Fashion Industry Charter for Climate Action.

In addition, the Global Environment Facility (GEF) can be recruited for realizing this implementation programme, as it is already committed to such work under GEF-8 programming directions. The GEF’s new Elimination of Hazardous Chemicals from Supply Chains Integrated Program commits the Facility to work on the textiles supply chain. A recently launched UNEP-implemented GEF project will work with four Asian nations – Bangladesh, Indonesia, Pakistan, and Viet Nam – representing 15% of global clothing exports to address chemicals of concern in their textiles industries.

The IOMC paper suggests engaging a candidate economic industry to develop, through dialogue, a sector vision and roadmap concerning important sustainability parameters, such as minimizing the use of hazardous substances, or advancing circularity objectives, which cover at least four areas:

• advancing the science on chemicals of concern;
• advancing green and sustainable chemistry technology innovation;
• strengthening regulations and policies; and
• mobilizing finance.

The textile sector already has a head start on this front, since it has been engaged with UNEP in dialogue to develop the aforementioned global roadmap for sustainability and circularity for the sector.

The paper further suggests that each sector and industry initiative outline specific measures or steps to take, such as:

• developing a list of hazardous substances causing concern in raw materials and supplies and production processes, such as a manufacturing restricted substances list (MRSL);
• developing standards that specify acceptable levels of chemical residues in finished products, either through a restricted substances list (RSL) or maximum residue levels;
• developing and implementing risk reduction measures to minimize occupational and public exposure, as well as emissions to air, land, and water, when hazardous substances cannot be phased out;
• identifying and implementing sustainable practices and alternatives, including through green and sustainable chemistry innovation, such as changes in processes, recipes, or product design, based on robust criteria and guidance on what constitutes safer alternatives; and
• developing sector-specific indicators to measure progress.

Here, too, the textile sector has a head start on these tasks. Oeko-Tex, the American Apparel & Footwear Association (AAFA), Apparel & Footwear International RSL Management Working Group (AFIRM), and Bluesign have developed RSLs, and most major brands have developed their own RSLs aligned with one or several of these four. Oeko-Tex and ZDHC have developed MRSLs, and individual companies, if they have an MRSL, tend to align theirs with ZDHC’s. There are also several relevant certification and labeling schemes (see Figure 1), and textile-sector goals and targets have been developed to provide indicators for measuring progress (see Figure 2).

Figure 1: Relevant restricted lists, certification schemes and labels regarding chemicals in textiles

Figure 2: Existing goals/targets regarding chemicals/circularity in textiles

Focusing on chemicals of concern in textile production under a future framework implementation programme

The textile sector may have a head start, but much work on chemicals management in the sector remains that could be taken up by an implementation programme under the new global chemicals and waste framework.

For example, while ZDHC’s MRSL is well regarded, its adherents currently account for only a limited percentage of the industry and the list notably is not taken up by the many small and medium-sized enterprises (SMEs) that comprise much of the textile value chain.

As for RSLs, while many companies have adopted their own, these vary, as do the competing attempts at developing harmonized RSLs (Okeo-Tex, AFIRM, AAFA). Furthermore, existing RSLs tend to reflect only the chemical restrictions currently in place by major regulators – primarily the European Union (EU) – and the principal international convention restricting hazardous substances, the Stockholm Convention on POPs. In addition, these restrictions cover only dozens of the thousands of chemicals used in textile production, usually do not address all categories of concern (prioritizing carcinogens, mutagens, and teratogens, but not always toxins to aquatic life, endocrine disruptors, allergens, or irritants), and involve substances selected on a slow substance-by-substance basis that requires years to arrive at final regulatory decisions.

Figure 3: A timeline of existing initiatives on chemicals of concern in textiles

What would it take to address all potential chemicals of concern in the textile value chain?

Among the fibers used in textile production globally in 2021, cotton has the largest share among natural fibers (22% of all fibers), and polyester the largest among synthetic fibers (54% of all fibers). Other inputs include man-made cellulosic fibers, nylon, acrylic, leather, wool, polyurethane, bamboo, and silk.

In the case of natural fibers, chemical use starts during farming. Cotton is a significant consumer of chemical pesticides and fertilizers. In 2019, cotton accounted for 4.71%, by value, of all the chemical pesticides sold globally, and 10.24%, by value of all insecticides used in global crop protection. In 2018, cotton accounted for around 4% of global nitrogen and phosphorus fertilizer consumption. A push for greater global adherence to an organic cotton or organic textile standard, while recognizing the need for in-conversion/ transitional periods and support for farmers to move towards organic practices, could significantly cut consumption of chemicals at this stage in the value chain.

Whether made from natural or synthetic fibers or some combination thereof, all textiles undergo significant chemical treatment at many production and processing stages before their sale to the final consumer.

Figure 4: Types of Chemicals Used in the Textiles Industry Source: Adapted from NRDC, A Review of PAS as a Chemical Class in the Textile Sector (2021)

Currently, obtaining complete, accurate, and up-to-date information on the number, volumes, and identities of the chemicals used in textile production is difficult. Two oft-cited estimates are that over 8,000 chemicals are used in textile production and that for every one kilogram (kg) of cotton textiles made, 0.35-1.5 kg of chemicals are used. However, the origins of both estimates are hard to pin down. These figures are also from over ten years ago and may not reflect current market realities.

A comprehensive survey, inventory, or database of chemicals used in textile production would be difficult to complete due to the complexity and global nature of the textiles value chain, involving stages and actors across many countries and jurisdictions with varying ranges of capacity, regulation, industry standards, and diligence. Inter-party communication about, and tracking of, chemicals used among the points in the chain is often minimal. A concerted effort by IOMC Participating Organizations, governments, industry (including SMEs), and non-governmental organizations (NGOs) from across the globe under the umbrella of an implementation programme such as the one the IOMC proposes might be able to accomplish this task.

Without better accounting of the universe of chemicals used in textiles production, it is difficult to identify, triage, assess, and regulate chemicals of concern, deciding which need to be banned, which need to be subjected to occupational exposure and/or emission limits (wet processing of textiles, for example, is a major source of wastewater discharges), and the presence of which chemicals in textile products (and at what levels) should be mandatory to disclose to consumers. Some have already been identified (see Figure 4), but the current extent of their use worldwide remains unclear – another data gap an implementation programme might address.

Figure 5: Some Chemicals of Concern Used in the Textiles Industry Source: Compiled by the author from various sources

The stakeholder consultation process involved in an implementation programme could address how to prioritize and allocate reviews of possible chemicals of concern, possibly through the chemical class or family approach instead of substance-by-substance, such as the Natural Resources Defense Council (NRDC) has suggested for PFAS. Identified chemicals of concern could be added to a globally harmonized MRSL. The value chain could then use the MRSL to prioritize chemicals for restrictions or phaseout and for targeting for substitution without waiting for regulatory agencies to act. A commonly agreed certification and/or labeling scheme could identify which brands and products align with the harmonized MRSL. In those cases where emissions or occupational exposure are involved, maximum permissible levels could be identified in accordance with best practice and shared as guidance across the value chain, as ZDHC is seeking to do with its wastewater guidelines.

Another chemicals in textiles issue an implementation programme might address is trade. Several recent studies have shown that even when a jurisdiction outlaws chemicals of concern in textiles, imported apparel found for retail sale in that jurisdiction still contains values violating the restrictions. The new programme can identify trade issues for follow-up in appropriate fora such as the World Trade Organization (WTO) and could also identify and/or provide support required to downstream chemical users, including SMEs.

A possible waste management component for a textiles sector implementation programme?

While SAICM has tended to focus more on chemicals management than waste issues, negotiators of the successor framework conceive of it addressing the latter as well. The IOMC’s proposal for an implementation programme reflects this expected broader mandate, although it elaborates on chemicals management but not on waste management.

The textiles sector is very wasteful and almost entirely linear, so there could be much to discuss under an implementation programme of the type conceived by the IOMC. While textile production volumes doubled from 2000-2015, the clothing utilization rate, that is the number of times a garment is worn before it ceases to be used, decreased by an average of 36%. Reportedly, more than half of “fast fashion” is disposed of within a year. Of the total fiber input used to produce clothing, 87% ends up being landfilled or incinerated – the equivalent of one garbage truck full of clothes disposed every second. Less than 1% of material used to produce clothing is recycled into new clothing, a recycling rate ranking below that of most single-use plastic packaging.

Figure 6: Global material flows for clothing in 2015

Source: Ellen MacArthur Foundation, A new textiles economy: Redesigning fashion’s future (2017)

Circularity goes well beyond waste management and recycling fibers. As outlined by UNEP (Figure 6), “reduce by design” aims to reduce the amount of material, particularly raw material, and hazardous chemicals consumed during production and during use, from the very beginning of product and service conceptualization. Production and consumption patterns as well as end-of-life processes of textile products are optimized via innovative product designs and business models, resulting in not only eliminated harmful impacts and waste but also improved social protections and business resilience. However, there is a need to reduce the harm of the linear textile system we have today, while preparing for the needs and wants of the circular textile system of tomorrow, and this includes better waste management.

Figure 7. A circular textile value chain

Source: UNEP, Sustainability and Circularity in the Textile Value Chain: Global Stocktaking (2021)

Strategies for a circular economy specific to the textiles value chain have been proposed by UNEP, the Ellen MacArthur Foundation, the EU, Germany, and the Netherlands. The UN Alliance for Sustainable Fashion has engaged the fashion industry in discussions on steps to create a circular economy in textiles, as has UNEP. The Global Fashion Agenda (GFA) has created a Global Circular Fashion Forum and worked with UNEP to identify and converge existing industry targets, including on smart material choices, resource stewardship (including a specific target on chemicals of concern management/phaseout), and circular systems. The GEF has already approved two projects on circular economy and textiles covering four African countries, one implemented by UNEP, the other by UNIDO.

Figure 8: A Timeline of select initiatives regarding a circular economy in textiles

Hence, the building blocks are there to work with in any waste management component of the proposed implementation programme and also look at circularity more widely (with a focus on chemicals), but a rationale for the value added that the SAICM successor can bring needs to be elaborated and the issues for the waste component to focus on remain to be fleshed out.

The new global chemicals and waste framework might contribute to the existing work on circularity in the textiles sector by:

• linking together the disparate country- and regional-focused initiatives, and giving them true global scope, while elevating the challenges and support required into strategic high-level discussions;
• broadening the circular textiles discussions to involve interested IOMC Participating Organizations that are not part of the UN system, such as the OECD and the World Bank, and tabling the central role of chemicals management for circularity in the discussions;
• engaging the GEF in helping to develop the initiative, since IOMC Participating Organizations UNEP, UNIDO, UNDP, and the World Bank are GEF Implementing Agencies, and GEF-8 envisions work in this vein;
• broadening the circular textiles discussions to include more parts of the textiles value chain than just apparel; and
• broadening the discussions beyond the limited group of major brands and retailers already involved in existing circular textile initiatives, particularly by engaging the many SMEs in the chain.

The Road to Bonn: Paving the way for textiles to take the spotlight in implementation of the new chemicals and waste framework

The IOMC plans a stakeholder consultation from 20-21 June 2023 to further flesh out ideas for a possible global programme on advancing chemicals and waste management in economic sectors and value chains. The IOMC, working with Participating Organizations, the SAICM Secretariat, and perhaps engaging the GEF Secretariat as well, should use the stakeholder consultation as a springboard for active dialogue with stakeholders in the months leading up to ICCM5 in September on which chemical-intensive sectors to focus on. The textiles sector is a good candidate to become one of the first focus sectors. With a view to presenting a robust proposal for consideration at ICCM5 in Bonn, the dialogue should outline and flesh out what an implementation programme for the textiles sector might look like, which chemicals and waste management issues the implementation programme could provide value added on and should address, and possible objectives, targets, and indicators for the programme. The dialogue might also highlight global work undertaken in the textile industry which could be relevant for other chemical-intensive sectors facing challenges.

* * *

This document has been developed within the framework of the Global Environment Facility (GEF) project ID: 9771 on Global Best Practices on Emerging Chemical Policy Issues of Concern under the Strategic Approach to International Chemicals Management (SAICM). This project is funded by the GEF, implemented by UNEP, and executed by the SAICM Secretariat. The International Institute for Sustainable Development acknowledges the financial contribution of the GEF to the development of this policy brief.

 This Policy Brief is the sixth in a series featuring cross-cutting topics relating to the sound management of chemicals and waste. It was written by Keith Ripley, Earth Negotiations Bulletin (ENB) team leader and writer. The series editor is Elena Kosolapova, Senior Policy Advisor, Tracking Progress Program, IISD.

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Two chemical groups recognized by SAICM that fall outside global agreements and have significant impacts on water, health, and biodiversity are endocrine disrupting chemicals (EDCs) and environmentally persistent pharmaceutical pollutants (EPPPs). SAICM recognized EDCs and EPPPs as emerging policy issues a decade ago, accelerating cooperative actions among governments and stakeholders to mobilize knowledge and awareness. EDCs and EPPPs are not only important topics for global governance on chemicals. Policy advancements addressing EDCs and EPPPs are also applicable to and can be strengthened by the voluntary commitments of the 2023 UN Water Conference, negotiations for a new international treaty on plastics and a science-policy body on chemicals and wastes, and the implementation of the Global Biodiversity Framework (GBF), among other decision-making forums.

EDC and EPPP Risks

Historically, the risks and harms of pollution have not been prioritized in policy agendas commensurate with their impact on the health of people and planet. Worldwide consumption and production patterns have pushed the planetary boundary for environmental pollutants past sustainability while at least 5,000 novel chemicals produced since 1950 are recognized to have nearly universal human exposure. Pollution contributes approximately 17-25% of the environmental burden of disease, or about 9 million deaths per year. This is a fraction of the amount of its sub-lethal harms that lead to a wide spectrum of diseases, many of which are not recognized.

In 2017, the global health community elevated the visibility of negative health outcomes from chemical pollution through the formation of a Lancet Commission on Pollution and Health, yet an assessment report five years later noted “strikingly little” progress within countries to address these challenges. In fact, the challenge is increasing according to the World Water Development Report 2023: globally, water use rises by 1% per year but, still, five of 11 target indicators for SDG 6 (clean water and sanitation) are not reported.

EDCs and EPPPs were recognized by SAICM as emerging pollutants of concern in 2012 at the third International Conference on Chemicals Management (ICCM3) and in 2015 at ICCM4, respectively, due to their health risks. Worldwide, nearly everyone is suspected to have EDCs in their blood. EDCs are also found in the blood of diverse species in many ecosystems, which creates specific risks for mammals, birds, fish, and some other species who have endocrine systems. Normal reproduction and development of current and future generations of humans and other species are jeopardized by EDCs. This is a risk that will grow with rising use of plastic – a major EDC source -, which is projected to triple by 2060.

The sub-lethal effects of EDCs are dangerous and long-lasting. EDCs alter natural mechanisms of development and normal physiologic function because they change the internal communication system – the hormone system – of the organism exposed, essentially resulting in a biological re-programming, de-programming, or mal-programming. They are also known to modify DNA regulation and expression, yielding heritable changes across multiple generations. In addition, EDCs are associated to secondary effects, such as increased likelihood of non-communicable diseases (NCDs).

Concentrations of EPPPs create low-dose drug mixtures that humans are exposed to in water, and at the same time, these substances can have complicated negative therapeutic impacts on other species. Drugs in the environment have the unintended consequence of having their intended effect on the physiology of other species. For example, antidepressants, analgesics, antimicrobials, and steroids like contraceptives alter behavior and feeding, renal function, natural decomposition of excrement, and feminization, fertility and fecundity, ultimately disturbing ecological relationships and life cycles. The intentional therapeutic design of pharmaceuticals also contributes to their persistence in ecosystems and risks to other species.

EDCs and EPPPs both have substantial negative impacts on water resources and water ecosystems. EDCs are found in diverse water ecosystems and in surface, ground, and drinking water. Many sectors contribute to the EDC “cocktails” in water resources because EDC production and use are central to agriculture (pesticides), houseware industry (plastics), electronics (plastics and heavy metals), cosmetics, and healthcare (plastics). EDCs also arise from industrial chemicals used to enhance other products, such as with flame retardant qualities. The exposure data on EDCs at the sectoral level can be staggering. For one, fruit and vegetable produce can carry dozens of endocrine disrupting residues from pesticides. Current data on a specific type of EDC with hydrophilic (water-loving) chemical properties, per- and polyfluoroalkyl substances (PFAs), show they are widespread across regions, and frequently detected in water regardless of proximity to point sources, carrying significant implications for public health. For instance, the European Environment Agency (EEA) observes that 14% of teenagers across nine countries have blood levels of PFAs above health guidance levels. Leading institutions generally conclude that the impacts of EDCs are underestimated. A focus on water pollution is important to the management of EDCs because, according to the Stockholm Convention on Persistent Organic Pollutants’ (POPs) Second Global Monitoring and Review, EDC concentrations in water serve as an important indicator to the effectiveness of policies to reduce their emissions.

Similarly, EPPPs mainly pollute water, contaminating surface water, groundwater, drinking water, and soil. The dominant emission pathway is urban wastewater discharge, with that from manufacturing, animal husbandry, and aquaculture also being significant. Findings from a report of 89 countries showed 992 active chemicals from pharmaceuticals or their transformation products are found in water and waste streams, and 703 of these were found in surface, ground, or drinking water. Another finding showed that 37 EPPPs exist in all five UN regions. At the same time, conclusions from a workshop on risks held by the World Health Organization (WHO) Regional Office for Europe concluded that no existing health-surveillance programmes are fully applicable for EPPPs.

Governance arrangements

EDCs and EPPPs slip through the cracks of existing environmental governance regimes. The risks of EDCs are well understood but constructing a regulatory framework that captures their complexity, prevalence, and life cycle in the environment is difficult. EDCs can contaminate soil, water, air, and food, and fall under numerous regulatory categories depending on what profession is assessing them. Under international environmental law they can be categorized as “POPs,” “hazardous waste,” “mercury products” and other “heavy metals,” “pesticides,” and “plastics.” In the health sector, they are discussed as “carcinogens,” “mutagens,” and “reprotoxicants.” Despite that EDCs link to a spectrum of governance instruments, and their global prevalence, major sources of EDCs are not being addressed at the global scale because no global instrument encompasses them comprehensively. Efforts at the sub-global and national level are similarly uneven and patchy. Thousands more chemicals are linked to endocrine disruption than the 1,400 currently documented as EDCs, and of those documented, less than 10% are being assessed and/or addressed through existing instruments and actions, worldwide.

A similar challenge exists for EPPPs, but for different reasons. Major multilateral environmental agreements (MEAs) addressing chemicals, namely the Stockholm Convention on POPs, the Basel Convention on Transboundary Movement of Hazardous Waste, the Rotterdam Convention on Prior Informed Consent (PIC), and the Minamata Convention on Mercury, explicitly exclude pharmaceuticals from consideration. The sheer volume of these substances in the environment warrants a more inclusive approach. In some high-income economies estimates suggest nearly 50% of the population uses pharmaceuticals at any given time. The cumulative outflow of pharmaceutical products in hospital and household water and waste streams is steadily growing but risk assessments are insufficient. For example, in the EU, more than 3,000 pharmaceuticals are distributed without an Environmental Risk Assessment (ERA).

Water policy should be a logical home for governance of EDCs and EPPPs, however in practice, there is a mismatch in scale. Most regulatory policies on water are at the local or regional level, or scoped for river basins, while the prevalence and distribution of EDCs and EPPPs are global and transboundary. Moreover, global health experts note that metrics for industrial water pollution were agreed as part of the SDGs but are underdeveloped. Under public health mandates, water and sanitation policies are not scoped to consider chemical pollutants comprehensively or, in some areas, prioritize water access over risks from chemical pollution. The WHO began a process of developing drinking water quality guidelines on PFAs in 2017.

SAICM mobilized a series of “cooperative actions” to stimulate progress on EDCs (2012) and EPPPs (2015), because a focus on research cannot alone be successful in driving policy action. In 2020, the UN Environment Programme (UNEP) issued ‘An Assessment Report on Issues of Concern: Chemicals and Waste Issues Posing Risks to Human Health and the Environment,’ in which it noted that despite some progress on EDCs and EPPPs, current actions were insufficient to address the global nature and/or full life cycle of these issues. In the report, UNEP identified a number of ways to develop and advance a landscape of governance approaches to EDCs, spanning agriculture policies, health and occupational policies, human rights, and the domains of biodiversity and climate change. UNEP also identified challenges and opportunities to shape the norms and policies in the sound management of EDCs:

• Bringing countries to the same level of awareness and knowledge, and ensuring regular periodicity of assessments and synthesis of scientific knowledge ready to be used in policy environments; and
• Bridging different approaches to assessing and managing EDCs, rectifying policy inconsistencies, data requirements, and joint assessments and strategies, with emphasis on the broad uptake of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

UNEP also identified challenges to making progress on EPPPs that include addressing barriers in existing norms and policies:

• The scope of pharmaceuticals addressed is limited by terminology “environmentally persistent,” which does not capture, for instance, those that are pseudo persistent and bioaccumulate or those whose short-term impacts are irreversible. One way forward is to expand this scope with simple, general criteria.
• Pharmaceutical waste prevention needs to be stepped up because contamination is expensive and technically difficult. Stakeholders need to encourage pharmaceutical manufacturers to be more engaged in “green pharmacy” approaches along the value chain.
• Support for addressing negative impacts of pharmaceuticals is needed in developing countries and economies in transition and needs to be tailored to the pharmaceuticals most prevalent in local wastewater in those areas.
• The system of Environmental Risk Assessments (ERAs) needs to be re-visioned to capture the existing risk of total pollution load. Thousands of pharmaceutical products are distributed without ERAs and are measured in surface water at significant concentrations.
• Strengthening the engagement of pharmaceutical manufacturers and capturing the full life cycle of a pharmaceutical product in policy actions are important.
• Moving beyond a focus on knowledge to policy actions is needed. A package of instruments that includes marketing authorization, take-back unused/expired drug programs, and waste treatment, among others, are required.

One issue linked to EPPPs – the increasing risk and threat of “superbugs” – is drawing increasing attention worldwide. The multifaceted problem due to the use of antimicrobial drugs in human, veterinary, and livestock agriculture is a significant issue under EPPPs. According to a 2023 report, ‘Bracing for Superbugs,’ UNEP says minimizing pharmaceuticals is “critical” to preventing antimicrobial resistance (AMR) and ecotoxicity. Antibiotics, antivirals, fungicides, and disinfectants flow in wastewater, but a fraction have been assessed. The scale and interconnectedness of AMR water contamination calls for a comprehensive, multi-sectoral response, including ‘upstream’ and ‘downstream’ interventions as well as enhanced data collection and research. Solutions include improved prevention and reduction in overuse, especially in the agriculture sector, and improved water, sanitation, and hygiene (WASH) programmes.

Financing the sound management of EDCs and EPPPs

Major risks and major costs present a dual challenge for the sound management of EDCs and EPPPs and new attention is needed to highlight the long-term financial impacts of these pollutants. Arguments that pollution is not cost-effective are “flawed and obsolete,” according to health experts. At the same time, new investments in cost-benefit analyses to unveil and communicate hidden costs of pollution are essential.

A 2015 estimate of the cost of inaction on EDCs in Europe totals EUR 157 billion, and similarly, projections to pre-emptively manage the costs of antimicrobial resistance (AMR) are between USD 4 billion – 9 billion per year (upstream) and USD 13 billion – 47 billion per year (downstream). Another gap area is the disproportionate lack of funding in research and design for hazard analysis. In 2013, the EEA noted that “over the past decade” 1% of research funding went to hazards while 99% went to product development. Some stakeholders advocate for a 0.5% chemicals tax on the USD 2.3 trillion profit from production of basic chemicals.

Human rights dimension of EDCs and EPPPs management

The UN Special Rapporteur on Toxics views exposure of people to harmful substances without their prior informed consent as a human rights issue. The Rapporteur outlines the human rights obligations of states on pollution and toxics, including to establish monitoring programmes, assess major sources of exposure, and provide the public with accurate, accessible information about risks to health, and to not cause pollution or exposure to toxic substances that violate the right to a clean, healthy, and sustainable environment recently recognized by the UN General Assembly (UNGA). Specifically, the Rapporteur notes that the “application and interpretation of the right to a safe, clean, healthy and sustainable environment in the context of pollution and toxic substances should be guided by the principles of prevention, precaution, non-discrimination and non-regression, and the polluter pays principle.” The UN Special Rapporteur on the Human Environment further states that a non-toxic environment depends on safe, sufficient water and healthy aquatic ecosystems, which should be managed with water plans that take a rights-based approach.

Pollution is a major cause of environmental injustice, and gender equity is receiving increasing attention in this regard. The disproportionate exposure and risks women face leads some stakeholders to underscore the importance of gender-responsive chemicals management, while eight countries have invested in a multi-year project to assess the EDC toxicity on the female reproductive system. SAICM recognizes that information on chemicals associated to endocrine disruption should not be confidential.

Opportunities to promote sound management of EDCs and EPPPs

The recently concluded UN 2023 Water Conference created an opportunity to elevate the importance of sound management of EDCs and EPPPs. One key focus could be incorporating their consideration in voluntary commitments that make up the Water Action Agenda, which could, for instance, emphasize or specify quantitative goals on pollution, and the interlinkages of the human right to a clean, healthy, sustainable environment and the right to water and sanitation. The High-level Political Forum on Sustainable Development (HLPF) in July 2023 where SDG 6 will undergo in-depth review, as well as the SDG Summit in September could both bring much-needed attention to the issue of EDCs’ and EPPPs’ sound management.

In addition, 2023 will be a busy year with high potential to advance more comprehensive global chemical governance that includes emerging policy issues. SAICM – a multistakeholder and multi-sectoral policy framework established in 2006 to mobilize action until 2020 – will undergo a critical review to determine the sound management of chemicals and waste beyond 2020. Key events contributing to this review are the resumed fourth session of the Intersessional Process for Considering SAICM and the Sound Management of Chemicals and Waste Beyond 2020 (IP4.3) and ICCM5 – a body whose aim is to promote chemical safety worldwide and whose mandate includes considering a new instrument to follow SAICM. Both of these events have been delayed since 2020 and will convene in September 2023. These forums provide opportunities to directly promote the management of EDCs and EPPPs as issues of concern.

In addition, UNEP’s intergovernmental negotiating committee (INC) on plastics will reconvene to continue deliberation on the design of a new international legally-binding instrument (ILB). The meeting will focus on the substantive scope of the treaty and its implementation and the form of the global agreement to which countries could commit. Some governments propose that the treaty be scoped to consider both socioeconomic and environmental considerations of plastics, which is a way to ensure space to consider EDCs and EPPPs under the health dimension of socioeconomic concerns.

The Open-ended Working Group for a science-policy panel for chemicals, waste, and pollution will also resume to advance discussion on the scope and concept of the new panel. The panel aims to provide policy-relevant scientific advice, and these talks provide another ripe moment to ensure that the mandate of the panel is broad enough to include impacts of EDCs across exposure routes (air, water, soil, food, and chemicals in products) and also explicitly include pharmaceuticals. The innovative horizon-scanning feature proposed for this panel is important for tackling emerging issues and facilitating early warning. The updated WHO report on the State of Science on Endocrine Disrupting Chemicals since 2012 is underway and anticipated prior to the sixth session of the UN Environment Assembly (UNEA) in 2024. Consideration for how the global health field can incorporate EDCs’ and EPPPs’ monitoring and actions to address them, such as through WASH programmes, would be a valuable chapter.

Other international forums and implementation actions provide additional opportunities to ensure water pollution, EDCs, and EPPPs are appropriately addressed and regulated at the global level. There are a number of biodiversity policy spaces that can strengthen uptake and capacity building for chemicals. GBF target 7 – to “reduce pollution risks and the negative impact of pollution from all sources, by 2030, to levels that are not harmful to biodiversity and ecosystem functions and services, considering cumulative effects,” including by halving nutrient loss and the risk of pesticide and highly hazardous chemicals, and by working towards eliminating plastic pollution – provides important synergies to chemicals governance spaces. Specific mention of water pollution from EDCs and EPPPs can be incorporated into updates of National Biodiversity Strategies and Action Plans (NBSAPs), which are currently underway. Development of One Health Action Plans is another vehicle where EDCs and EPPPs are relevant, such as within management strategies for antimicrobial drugs.

A renewed focus on gaps in national implementation and agenda setting is a way to take up global health recommendations. A 2022 Lancet Commission on pollution and health progress report on national water governance underlined the importance of cross-sectoral approaches to pollution control policies. The report observed that “ministries of health continue to prioritise infectious diseases and disease treatment, leaving pollution prevention to the ministries of environment, which usually have less power and less funding than ministries of health,” and further noted the absence of leadership from powerful ministries of finance, urban development, and energy.

Advancing effective pollution control for water resources, EDCs, and EPPPs will require the involvement of the health sector at the national level, particularly in the development of evidence reports, action plans, and communication. Some countries are making progress on EDCs, including Belgium, France, Japan, and Malaysia, though a recent analysis of regulatory approaches points to major technical barriers, such as the in vivo evidence requirement to demonstrate EDCs’ adverse effects. On pharmaceuticals, the Netherlands, Sweden, and China have developed progressive approaches. However, significant imbalance exists in the assessment and monitoring of chemicals, including EDCs and EPPPs, across regions. The Lancet report offers several recommendations to develop health sector involvement, including:

• Establishing monitoring and control systems on different forms of exposure, such as developmental toxicity, reproductive toxicity, immunotoxicity, the effects of long-term low-level exposures, and the health risks of chemical mixtures, such as by building on hazard identification models;
• Incorporating pollution prevention into development strategy frameworks;
• Strengthening media attention to topics relating to pollution and health;
• Including modern pollution prevention in multilateral development institutions’ country strategy frameworks;
• Linking pollution to planning for noncommunicable disease, climate change, biodiversity, food, and agriculture, and making pollution a more robust component of the One Health approach and in dialogues on planetary health; and
• Identifying and mapping pollution exposures particularly in low-income and middle-income countries.

A stronger mention of pollution in the Global Action Plan for the Prevention and Control of Non-Communicable Diseases would provide top-down support to national planning.

UNEP’s Assessment Report on Issues of Concern concluded by highlighting looking not only at risks to human health and the environment, but also at the links between chemicals and waste and other environmental and societal priorities. The year 2023 offers many doors to improving the global best practices on emerging issues in chemicals governance.

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This document has been developed within the framework of the Global Environment Facility (GEF) project ID: 9771 on Global Best Practices on Emerging Chemical Policy Issues of Concern under the Strategic Approach to International Chemicals Management (SAICM). This project is funded by the GEF, implemented by UNEP, and executed by the SAICM Secretariat. The International Institute for Sustainable Development acknowledges the financial contribution of the GEF to the development of this policy brief.

 This Policy Brief is the fourth in a series featuring cross-cutting topics relating to the sound management of chemicals and waste. It was written by Liz Willetts, IISD Earth Negotiations Bulletin (ENB) Team Leader and Senior Writer. The series editor is Elena Kosolapova, Senior Policy Advisor, Tracking Progress Program, IISD.

RELATED EVENTS

• Fifth Meeting of the International Conference on Chemicals Management (ICCM5)
• UN 2023 Water Conference