Orgalime recommendations on REACH
Notwithstanding the improvements that have been made since the Internet consultation document, Orgalime is still concerned that the REACH proposal, if adopted in its present form, will impose burdensome bureaucratic constraints and impede the competitiveness of our industries. Orgalime therefore provides in the enclosed document its key recommendations in order to shape the REACH proposal. Orgalime believes that, from its downstream user's perspective, the future legislation on REACH should enshrine the following principles :
- Safeguarding of the innovation capacities and competitiveness of European engineering industries
- Consistency with other existing legislation, such as product specific or occupational health and safety legislation
- Clear and justified responsibilities in the supply chain should mirror the individual role and competence of the economic actor in the chain
- Proper information along the supply chain.
Related Position Papers
Green Transition: Joint Business statement on the Corporate Sustainability Due Diligence Directive (CS3D) [30 May 2023]
Green Transition: Joint Business Statement on the due diligence proposal (CS3D) [19 January 2023]
Environment: Orgalim preliminary key messages for the upcoming revision of the EU Waste Framework Directive Orgalim [11 August 2022]
Environment: Position and recommendations from Europe’s technology industries on the proposed Ecodesign for Sustainable Products Regulation [1 June 2022]
Environment: Orgalim position paper on the upcoming revision of the RoHS Directive [31 May 2022]
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]