Orgalime key messages on REACH

Published: 19 October 2004

Policies & Issues: Environment

Orgalime recommends to the European institutions to shape the REACH proposal in a way that would fully mirror the different roles and responsibilities of the individual actors in the supply chain. From our second level downstream user perspective we highlight the following key areas:

- Harmonisation at both, global and European level

- Introduction of clear, simple, broad exposure and application categories instead of the concept of "identified use"

- The availability of substances is a core element of innovation and competitiveness of European engineering industries

- Information passed on in the supply chain should be harmonised, simple, straightforward and operational

- Substances in articles, waste and basic raw materials for the metal industry should not fall under REACH

- REACH should not overlap with specific product related legislation for engineering products nor with other legislation, such as occupational health and safety or specific environmental legislation

- REACH should establish a risk based priority system

Related Position Papers

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]

Environment: Orgalim response to the consultation by the Platform on Sustainable Finance on EU taxonomy [5 October 2021]

Environment: Joint statement on the need for a transition period for the implementation of the Batteries Regulation [28 July 2021]