Input to the review study of the scope of REACH & other EU Legislation to assess overlaps & gaps

Published: 27 July 2010

Policies & Issues: Environment

Orgalime appreciates the possibility to contribute with its comments to the study on scope of REACH and other relevant EU legislation with a view to assessing possible overlaps and gaps.

The EU’s horizontal chemicals law, the REACH Regulation based on article 95, aims at fully harmonising the EU’s framework for the management of chemicals, including substance registration, evaluation, restriction and authorisation requirements and uses of substances in the EU.  However, despite the adoption of the REACH Regulation in 2006, several pieces of other EU legislation affecting Orgalime industries continue to include and/or introduce new provisions related to chemical substances, which often create overlaps, legal uncertainty and unnecessary duplication of law, administrative burden and costs.

The main consequence of this is that cohesion and consistency are not fully secured for European engineering industries, while at the same time unclear legal requirements also weaken environmental objectives and proper enforcement of law.

Related Position Papers

Environment: Orgalim position on the Sustainable Products Initiative [8 June 2021]

Environment: Orgalim position on draft reporting rules for companies under the EU Taxonomy Regulation [2 June 2021]

Environment: Orgalim position on the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024 [2 June 2021]

Environment: Orgalim comments on the REACH revision roadmap [1 June 2021]

Environment: Orgalim comments on the French draft decrees on the identification of hazardous substances and the provision of information identifying endocrine disruptors in products [22 March 2021]

Environment: Orgalim comments on a proposal for a Regulation for Batteries and Waste Batteries [1 March 2021]

Environment: Orgalim comments on the 1st draft delegated act on climate change sustainable activities supplementing the EU Taxonomy Regulation [18 December 2020]

Environment: Orgalim views and recommendations on the Sustainable Products Initiative [16 November 2020]

Environment: Orgalim position paper on the new Circular Economy Action Plan [15 October 2020]