Environment: Orgalim comments on the REACH revision roadmap

Published: 1 June 2021

Policies & Issues: Environment

Orgalim, representing Europe’s technology industries, welcomes the revision of European Union legislation on registration, evaluation, authorisation and restriction of chemicals (REACH Regulation). Our technology industries, major downstream users and article manufacturers are fully committed to reducing the content of hazardous substances in their products to support a more circular economy.

Here are our key messages on the REACH revision inception impact assessment roadmap:

  • We call on the ECHA and the European Commission to develop better criteria for determining when authorisation and when restriction is applicable. 

  • Industry needs to be able to continue producing products using chemicals in a level playing field with non-EU countries. Therefore, a REACH restriction rather than authorisation is the preferred instrument to regulate chemicals.

  • We urge to keep the scope of REACH Article 33 limited to Substances of Very High Concern (SVHC) and to not broaden the scope to Substances of Concern (SoC). However, if that were to be the case, we would call for a clear definition of Substances of Concern in order to ensure legal certainty and clear procedure rules.

  • REACH should continue to be the main instrument for evaluating and identifying SVHCs with the goal of restricting or authorising them.

  • Policymaking and decisions regarding chemicals should be risk-based not hazard-based.

  • The use of a SVHC and its health impact on workers and consumers should be re-evaluated before a substance is put on the candidate list, with actual data provided by the affected industry accurately assessing the risk of a substance based on its probability of exposure and the health impact.

  • Socio-economic factors should be considered earlier from the industry aspect. It should be evaluated in advance whether the consequences of a restriction or authorisation scenario are proportionate to the anticipated benefits to the environment and to health.


To read our recommendations in full, please download the document above.


Timothée Tierny
Junior Adviser - Energy and Environment

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