H&M Group’s position on safe-by-design chemicals definition to drive circular economy


H&M Group has the ambition to become 100% fair and equal, 100% circular and climate positive. Circular products mean products that are made to last, from safe, recycled and sustainably sourced input that can recirculate multiple times. Chemical management is an essential part of our circular ambition: our vision is to lead the change towards safe products and toxic-free fashion. H&M Group’s Chemical Roadmap is our major tool to reach our overarching goal: toxic-free fashion by 2030.

We support the European Commission’s holistic and coordinated approach to accelerate circular economy in the industry. The harmonisation and definition of one common legal and implementation scheme will allow the fashion industry to contribute to the Green Deal vision and transition to a circular and carbon neutrality by 2050. To put sustainability at the core of our industry is a big opportunity to accelerate the pace of change and drive for a Green Recovery.

In this context, H&M Group values the opportunity to contribute to the current debate on the definition of chemicals that are safe and sustainable-by-design under the EU Chemicals Strategy for sustainability – and to be taken into account under the Sustainable Product Initiative as well as under the EU Textile Strategy.

As a downstream user of chemicals, we experience a gap in how hazards are communicated in a clear, harmonised, and transparent way. This gap continuously poses a problem while working towards our vision of a toxic-free fashion future, for example in substitution of hazardous chemicals and our aim of promoting best available chemicals. At H&M Group, we therefore see a need to establish an acknowledged and harmonised hazard assessment methodology to future-proof circular products.

While reading the EU Chemical Strategy, the European Commission’s first attempt at defining safe and sustainable- by-design chemicals caught our attention (EU Chemical Strategy, EC COM(2020) 667 final, p. 4, note 19).

We would like to seize the opportunity to further delve into the concept of safe. We agree with what we interpret as a definition in line with the “prevent, prioritize, remove hierarchy”, where minimising volumes and the environmental footprint of chemicals before they are placed on the market is important.

H&M Group’s chemical approach

At H&M Group, it is, and has long been, evident that we must avoid and restrict substances of concern (health and environment, including, but not limited to, Substances of Very High Concern (SVHC) as defined in Articles 57-59 of the REACH Regulation (EC) No 1907/20069) in our products as well as in their manufacturing processes. Not only for the safety of our customers and the environment, but because it is our responsibility as a leading global fashion company to use our size and scale to create positive change. H&M Group Chemical Restrictions were among the first in our industry.

We are constantly monitoring progress of substances’ hazard evaluations, making sure that our Chemical Restrictions are up to date with recent research. Where required, the precautionary principle is applied to phase out substances before consensus has been reached e.g., on specific hazard category.

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Chemsec, 15 April 2021
; https://chemsec.org/hm-groups-position-on-safe-by-design-chemicals-definition-to-drive-circular-economy/