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

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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]

Environment: Financing key enablers of the green transition: Orgalim position on the EU taxonomy for sustainable activities [6 October 2021]