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must be ensured and sufficient time frames for finding substitutes for any substance that is called upon to be withdrawn must be provided.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: 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]

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

Environment: 40 industry organisations call for urgent actions to postpone the legal obligations to the ECHA SCIP database [21 September 2020]

Environment: Joint industry statement on the impact of restricting primary batteries in Europe [15 September 2020]

Environment: Orgalim calls for an impact assessment and a delay of implementation of ECHA SCIP database [30 June 2020]

Environment: Orgalim comments on the development of sustainability requirements for batteries under a New Regulatory Framework for Batteries [26 June 2020]

Environment: Wastewater matters too: Orgalim’s recommendations for the revision of the Urban Waste Water Treatment Directive [22 May 2020]

Environment: Think Blue: Orgalim recommendations for the improvement of the Water Framework Directive [22 May 2020]