Orgalime recommendations on REACH
Published: 10 May 2005
Policies & Issues: Environment
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.