The PINK project was invited to provide technical comments on the Revised SSbD Framework of the JRC of the EC.
Image: Courtesy of the EC, DG RTD
The Safe and Sustainable by Design (SSbD) Framework is a key initiative of the European Commission intended to guide the development of chemicals and advanced materials that are both safe for human health and environmentally sustainable. It aims to integrate safety, environmental sustainability, functionality, and socio-economic considerations from the earliest stages of material development through production, use, and end-of-life management.
A central feature of the SSbD approach is its tiered and iterative assessment process. It begins with a scoping phase in which the purpose of the innovation, its functionality, and the relevant value chain context are defined. Based on this foundation, developers perform safety and sustainability assessments at increasing levels of detail as more information becomes available and the technology matures. This structure is intended to support innovation while ensuring that potential risks and environmental impacts are identified and addressed early in the design process.
The framework also emphasizes life-cycle thinking, transparency, and documentation. By assessing materials across their entire life cycle and documenting design decisions and evaluation steps, SSbD aims to support responsible innovation and align new materials and chemicals with broader European sustainability and competitiveness goals.
Feedback and Proposals from the PINK Project
Partners of the Horizon Europe project PINK generally welcome the revised SSbD framework and its stronger focus on the scoping phase and incremental innovation. However, the consortium identified several areas where clarification and methodological improvements would strengthen the framework and make it easier to apply in practice.
Clarifying Roles and Responsibilities: The framework introduces roles such as “SSbD assessor” or “SSbD practitioner.” PINK partners suggest that SSbD cannot realistically be implemented by a single individual. Instead, it should be carried out by a multidisciplinary team covering safety, environmental sustainability, functionality, and socio-economic aspects. The process should be coordinated by a project or innovation leader while involving all contributors to the material development process.
Improving the Scoping Phase: The scoping phase is considered a critical starting point but would benefit from clearer methodological guidance. In particular, the framework should provide more detailed instructions on defining system boundaries, identifying relevant actors in the value chain, and documenting comparative assessments between different candidate materials. Innovation often involves selecting the most suitable option from several possible materials or designs. PINK partners therefore recommend that the framework better reflect comparative decision-making processes during innovation. They also suggest further clarification of the concept of “scenarios,” including greater emphasis on multi-stakeholder value-chain approaches, rather than assuming innovation originates in a single company.
Integrating Safety and Sustainability Assessments: The revised framework allows both hazard-based and exposure-based approaches for safety assessment, which is welcomed by the PINK consortium. However, the relationship between these approaches requires clearer explanation. In practice, both hazard and exposure information are needed to conduct a meaningful risk assessment, and the framework should describe more clearly how these elements interact throughout the evaluation process. The link between safety assessment and sustainability analysis, including life-cycle considerations, should be strengthened to avoid creating separate or disconnected evaluation processes.
Providing Clearer Guidance on Indicators and Decision Rules: PINK partners note that users of the framework would benefit from more detailed guidance on indicator selection, decision rules, and methodological criteria. Some figures, tables, and conceptual illustrations in the framework could also be simplified or clarified to improve their interpretability. Another important point concerns documentation throughout the SSbD process. Rather than treating documentation as a final step, it should be embedded in every phase of the assessment to ensure traceability of design choices, data inputs, and evaluation results.
Strengthening Data Management and FAIR Principles: The PINK consortium highlights the importance of robust data management practices, particularly the adoption of FAIR data principles, ensuring that data are findable, accessible, interoperable, and reusable. SSbD relies on iterative data flows across disciplines such as toxicology, environmental assessment, engineering design, and socio-economic analysis. FAIR data infrastructures enable these domains to exchange information effectively and support the integration of modelling tools, experimental data, and life-cycle assessments within digital decision-support systems. PINK partners therefore recommend that FAIR data principles be explicitly integrated into the framework and connected to emerging digital policy initiatives such as digital product or materials passports.
Recommendations for Future Methodological Guidance: The consortium suggests that future methodological guidance should provide clearer recommendations on data documentation, quality assurance, and access to underlying raw data. Integrating methodological guidance more closely with the main SSbD framework would also improve usability for practitioners and researchers. The PINK project supports the objectives of the SSbD framework and sees strong potential for it to guide responsible innovation in chemicals and advanced materials. At the same time, the consortium’s feedback highlights the need for clearer definitions, stronger methodological guidance, improved integration of assessment dimensions, and robust data infrastructures to ensure that the framework can be effectively implemented in real-world innovation processes.
The Revised SSbD Framework from JRC may be downloaded here.
