Responses to questions asked during the April 22^nd webinar launch of the Change Chemistry/UMass Lowell report Incentivizing Sustainable Chemicals: A Policy Framework for Innovation, Manufacturing, and Market Transformation

      1.    Do you believe that incentivizing/promoting sustainable chemistry will help increase trust by the general public in chemistry and science? 

As we have seen in the green chemistry education space, if chemicals provide useful functions and are safer, healthier and more sustainable and there is greater transparency along value chains, that can have a benefit in increasing trust in science. Of course, sustainable chemistry alone can't solve that problem. 

       2.    At least in the EU the chemical industry has successfully carved out exceptions in various policies (ETS, CBAM, ESPR, lead markets) by arguing that with 75,000 different products the chemical supply chains are just too complex to be effectively governed. What is your response to addressing this complexity? 

Yes, chemistry and chemical supply chains are complex. But other sectors and technology systems are complex.   Having good chemical information: production, value chains, use, etc. can permit prioritization. Complexity shouldn't be a reason NOT to act but a challenge to solve. Sectoral, functional class, or product class approaches can help simplify the chemistry issue. For example, of the tens of thousands of chemicals there are only about 200 functional classifications for chemicals in the literature.  

      3.    Many, if not most, substances are hazardous, and public resources are limited; where should authorities focus their efforts for looking for / supporting development and uptake of alternatives?  

The question of priorities is critical, given fiscal constraints. If we keep the focus on incentives, prioritization can be guided by both hazard and the availability of alternatives. There are many high-concern substances where alternatives are still lacking, and advancing restrictions alone could overwhelm regulatory systems through authorizations and exemptions. A focus on incentives to steer innovation where it is needed and to reduce business risk (such as subsidizing first-of-a-kind facilities) to help sustainable chemistry solutions to reach the market. Incentives can be designed to not only relieve pressure on regulatory systems, but also ensure that when policy signals tighten, there are practical, scalable alternatives ready to meet them. Programs that incentivize safer chemicals across sectors or product classes like the EPA safer choice program can address multiple chemistries at once. 

      4.    The willingness to convert to more sustainable alternatives is highly dependent on the sector of use. Should we focus on early movers, such as cosmetics sector? Or instead on sectors with complex value chains and sustainability issues, such as electronics? 

We think it’s less about choosing one sector over another and more about sequencing and tailoring strategies that are coordinated across the whole of government. As you infer, different sectors face different barriers, so the role of incentives—and policy more broadly—will vary. Early-mover sectors like cosmetics can deliver near-term wins and show proof of concept. They often have clearer consumer signals, shorter innovation cycles, willingness to pay a price premium, and smaller volumes. Focusing here can demonstrate feasibility, build market confidence, and create visible success stories that help normalize substitution. At the same time, more complex sectors like electronics or automative are where many higher-impact challenges sit—long supply chains, strict performance requirements, and limited transparency. These sectors may require more targeted, sustained incentives—such as coordinated R&D, or use of time-bound purchase commitments for products that meet safer chemistry criteria to reduce risk for manufacturers' reformulating materials. We might look at examples in the semiconductor industry where some countries have offered subsidies or tax incentives tied to enhancing domestic capacity. These could be conditioned on the use of transitions towards sustainable chemistries/safer alternatives.   

      5.    The regulatory incentives seem to be focused on taxes and fees. What other regulatory incentives for sustainable chemistry, or against legacy chemistry, were considered? 

In the realm of regulatory incentives, we didn’t look specifically at regulation as an option but it is a key motivator for sustainable chemistry. Fees and taxes were the focus. We’d be interested in exploring other ideas. Some others were encompassed in a report we completed for the state of California in 2024 - - https://www.sustainablechemistrycatalyst.org/s/Sustainable_Fees_Policy_Options_Report.pdf  

      6.    A question that I increasingly juggle with is that for issues like climate or nature the 'issue' is a negative externality that we want to reduce. But with chemicals, we are dealing with a commodity that is marketed for a particular purpose and this commodity might have a negative externality. Can the multiple incentives ever override the need for significant profit margin of the commodity beyond the niches that we already see? How do we get past this? Back to polluter pays that formed the basis of environmental legislation. 

We’ve often thought about the externalities associated with toxic chemicals, but as noted, chemicals are different from issues like climate in that we’re not eliminating a single externality but rather reconfiguring the inputs to products that deliver value. That makes the problem more inherently complex, especially where--as we stated on the webinar—problematic incumbent chemistries are cheap, well-performing and deeply embedded in existing supply chains.  In that context, incentives alone are unlikely to overcome profit margins alone.  The solutions have to get to scale to reduce costs relative to incumbents but also incentives on incumbents need to be shifted. Incentives are likely most effective at shifting the frontier—supporting innovation, early adoption, and reducing the cost and risk of transition. But to move beyond niche markets, they typically need to be paired with clear policy signals that seek to internalize externalities. This is where principles like polluter pays still matter—but in practice, they often operate through a mix of tools, such as regulatory  (restrictions, phase-outs, or essential-use frameworks) that reset the baseline; demand-push incentives (e.g., extended producer responsibility, fees, or differential pricing) that begin to reflect true costs; other policy incentives (e.g., time bound tax credits or subsidies, cost-sharing/technical assistance programs) that accelerate the availability and uptake of alternatives so those policy shifts are feasible.  We see that a goal isn’t for incentives to “outcompete” profit margins indefinitely, but to change the underlying economics over time—so safer and more sustainable chemistries become the competitive default, not the exception. This isn’t about choosing between incentives and polluter pay measures—it’s about sequencing and combining them so that markets are both pushed and pulled toward safer outcomes. 

      7.    The report / discussion is very strong on de-risking and incentivising sustainable chemistry. How do you see this sitting alongside ‘polluter pays’ type instruments - particularly upstream signals on fossil-based feedstocks or petrochemicals - both to correct cost distortions from incumbent chemistries and to help fund these incentives? 

See earlier question.  Internalizing externalized costs and risks through policy and market measures can help shift markets over time.

      8.    Since chemical supply chains and rules vary so much by region, do you think the policy framework you've proposed (which seem to focus on the US and EU) would also work in Asia or other developing countries? 

There’s nothing inherently region-specific about these measures. The examples as well as our research are primarily drawn from experience in the EU and US, but the underlying mechanisms are broadly applicable. That said, how they are deployed will likely look different depending on the governance structures and market conditions.  In regions where state-owned enterprises or more centralized industrial policy are the norm, governments have more direct levers to shape outcomes and have an ability to set longer term plans.  In other settings, where markets are more decentralized, incentives tend to focus more on de-risking private investment and coordinating across complex value chains. So the framework is transferable, but it’s not one-size-fits-all—the key is to align policy incentive combinations with institutional structures, supply chain dynamics, and development priorities. 

      9.    Are scientific and substitution support institutes on your radar, and if not, what does that tell us about the information gap between green chemistry infrastructure and corporate R&D pipelines? 

These resources/examples are definitely on our radar. They are in part a form of ecosystem support subsidies that we discuss in the report where shared services, or other types of institutional support are provided to foster innovation, commercialization and/or adoption of safer alternatives. What’s particularly interesting about the EU Substitution Center model that is that it’s not just innovation support—it’s also a response to regulatory bottlenecks, especially under REACH where the volume of authorisation applications can exceed the capacity of authorities to review them efficiently. In large measure, the implementation of such Centres would help shift effort and resources upstream to more strongly focus on substitution, rather than resources spent to review justifications for continued use of problematic substances. The fact that these resources aren’t always integrated into corporate R&D pipelines does point to a persistent gap. Are regulatory signals “sticks” not working as intended? Could use of incentives also be used to provide a “carrot”?  How can these be better connected?

      10.    A very good point was raised: policymakers need to understand how it all works from a supply chain perspective.   
•    This is a map of the Textile/Apparel and Chemistry Supply Chain as an illustrative example:  
•    https://www.dropbox.com/scl/fi/d3pdp44urovhrgiqkuis6/PDF-The-Supply-Network-v7.0-November-2024.pdf?rlkey=93kue4irdtdiv7ogugl9qcypz&e=2&st=ix4eohdr&dl=0