The European Union’s Plastics Strategy, announced in January 2018, marked a turning point in efforts to reduce environmental harm from plastics while promoting circular economy principles. At its core, the strategy called for systemic changes in the production, use, and disposal of plastic materials. One of its most significant implications for industry was the increased emphasis on transparency in chemical composition across supply chains, laying the groundwork for more stringent regulatory requirements that would follow. For chemical manufacturers and plastics processors, this signaled the need to take proactive steps toward supplier-level disclosure, even in advance of formal mandates such as those tied to the SCIP (Substances of Concern In articles as such or in complex objects (Products)) database maintained by the European Chemicals Agency (ECHA).
While the SCIP database itself would not be operational until 2021, its conceptual foundations were evident in the 2018 Plastics Strategy. The call for greater visibility into chemical content aligned with broader EU policy trends, including the drive to minimize the presence of hazardous substances in products and to enhance material traceability for recycling and reuse. For suppliers of polymers, additives, and related chemical inputs, this created both challenges and opportunities. Early adopters who began aligning internal systems with future disclosure frameworks positioned themselves to navigate the coming regulatory landscape more efficiently and to respond to customer and market expectations regarding transparency.
One of the practical steps available to chemical companies in 2018 was to use the developing criteria of the SCIP database as a benchmark for internal assessments. This meant taking inventory of polymer formulations and mapping them against existing restricted-substance lists, such as those defined under REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals). The exercise required collaboration across technical, regulatory, and procurement teams to compile detailed data on ingredients and their concentrations, as well as on the origins of constituent substances. For many firms, this process revealed gaps in supplier documentation and prompted efforts to improve the quality and granularity of information obtained from upstream partners.
Establishing robust chemical footprint disclosures at the supplier level required a methodical approach. Companies first needed to build or upgrade data management systems capable of handling complex material composition data and linking it to specific suppliers and production batches. Such systems had to be flexible enough to accommodate evolving regulatory lists and adaptable to multiple reporting formats, as different customers and jurisdictions would inevitably demand varying levels of detail. Beyond the technical infrastructure, companies had to foster a culture of transparency throughout the supply chain, encouraging suppliers to share full material disclosure where feasible and to provide assurances regarding compliance with relevant restrictions.
The Plastics Strategy also underscored the importance of harmonizing chemical disclosure practices with circular economy objectives. In practical terms, this meant that data collected for compliance purposes could be leveraged to support design for recyclability, safe material recovery, and responsible end-of-life management. Suppliers who integrated chemical footprinting into broader product stewardship initiatives found themselves better positioned to meet customer requirements and to contribute meaningfully to industry-wide sustainability goals. The interplay between regulatory preparedness and market differentiation became increasingly clear, as buyers and downstream users began placing greater emphasis on sourcing materials with documented, low-risk chemical profiles.
Preparing annual chemical footprint disclosures served multiple functions. Not only did it provide a mechanism for tracking and demonstrating compliance over time, but it also offered a framework for continuous improvement. By documenting the presence and management of substances of concern, companies could identify trends, set reduction targets, and monitor progress against internal or sectoral benchmarks. Templates for these disclosures typically included summaries of material types, associated restricted substances, mitigation measures undertaken, and engagement efforts with suppliers to address identified risks. The value of such reports extended beyond regulatory audiences, supporting communications with customers, investors, and other stakeholders interested in corporate responsibility and sustainability.
Looking ahead from 2018, it was evident that the EU Plastics Strategy had begun to reshape expectations regarding supply chain transparency in the chemical sector. While the regulatory apparatus for detailed chemical disclosure would take several more years to materialize fully, forward-looking firms recognized the advantages of getting ahead of the curve. By aligning internal practices with emerging frameworks like the SCIP database and integrating chemical footprinting into core business processes, they laid the foundation for more resilient, compliant, and market-responsive operations in a rapidly changing policy environment.