The substitution principle in chemical regulation: a constructive critique

The substitution principle is one of the building blocks of modern day chemical regulation as highlighted in the registration, evaluation, authorisation and restriction of chemicals regulation. But what is the substitution principle, what is the history of its use and how do relevant authorities and regulatory actors view it? This article addresses these questions and is based on a grey literature review and 90 in-depth face-to-face formal and informal interviews with leading policy-makers in Europe, with a specific focus on Scandinavia. The paper shows that the substitution principle is surprisingly under researched topic and that there is no clear consensus on how to best apply the principle. The penultimate section puts forward a series of recommendations with regard to the use of the substitution principle that European policy-makers and regulators may wish to adopt.