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must be ensured and sufficient time frames for finding substitutes for any substance that is called upon to be withdrawn must be provided.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

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]