Industry’s view on the Roadmap on Substances of Very High Concern

Published: 12 March 2013

Policies & Issues: Environment

The first industry experiences with the authorisation process are that this process is not just limited to manufacturers and/or importers.  Downstream users also clearly play a much more important role than ever anticipated.  It is in the authorisation process that the complexity of REACH is becoming increasingly evident across the entire supply chain. Experience so far with entering substances on the Candidate List and afterwards prioritising for Authorisation by inclusion in Annex XIV, have shown an underestimation of the complexity of the supply chain and demonstrate unforeseen impacts right down to the end of the supply chain, including recycling.

Therefore industry - indicated on the cover page - representing the interest of manufacturers, distributors, immediate downstream users and down to the ultimate end-users, do see the need to have a roadmap on Substances of Very High Concern.  This would be a first step towards a harmonised approach that is used by member states and the Commission to identify relevant potential substances for the Candidate List.  A transparent and predictable process is needed to avoid issues such as supply chain disruption, and would be consistent with one of the primary aims of REACH and of authorisation, which is to ensure the efficient functioning of the internal market.

Related Position Papers

Environment: Orgalim preliminary key messages for the upcoming revision of the EU Waste Framework Directive Orgalim [11 August 2022]

Environment: Position and recommendations from Europe’s technology industries on the proposed Ecodesign for Sustainable Products Regulation [1 June 2022]

Environment: Orgalim position paper on the upcoming revision of the RoHS Directive [31 May 2022]

Environment: Orgalim position on the upcoming revision of the REACH Regulation [13 April 2022]

Environment: Orgalim Position Paper on the “right to repair” [5 April 2022]

Environment: Orgalim Position Paper on the restriction of PFAS [27 January 2022]

Environment: Orgalim Position Paper on the draft French Decree on consumer information for waste-generating products [21 December 2021]

Environment: Joint industry position paper on the concept of Essential Use [3 November 2021]

Environment: Orgalim comments on the draft French Decree on the minimum proportion of reused packaging [28 October 2021]