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

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.