Orgalime position on REACH Consultation documents

Published: 9 July 2003

Policies & Issues: Environment

Orgalime understands the intention of the Commission to address the current lack of information and knowledge about the extremely broad variety of different chemical substances for environmental, health and safety reasons.
However, we believe that the draft REACH proposal calls for in depth revision particularly along the following principles:

· Downstream user concerns must be assessed by undertaking a specific downstream user impact assessment in line with the better regulation principles.

· Market reality of companies that are acting in rapidly evolving market places where time to market is essential for business success must be taken into account.

· The definition of "downstream user" needs to be revised in order to address the risk of a substance as early as possible in the supply chain.

· The availability of substances must be ensured and sufficient time frames for finding substitutes for any substance that is called upon to be withdrawn must be provided.

· The multiplication of administrative work in the supply chain, in particular for SMEs, must absolutely be avoided. Simplicity is a must.

· Any future system should follow a priority system tackling substances with highest negative impacts on human health or the environment first and addressing the uses of concern based on risk rather than hazard.

· The disclosure of proprietary and confidential business data and internal company know how must be prevented.
Orgalime urges the Commission to seriously consider the impact of the proposed draft REACH regulation on all dimensions of sustainable development, i.e. environmental, social and economic, before advancing further with this proposal.

Related Position Papers

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

Environment: Orgalim input to the European Commission consultation on the Revision of the Urban Waste Water Treatment Directive [20 July 2021]

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]