Risk Management Options (RMO) Analysis following the SVHC Roadmap to 2020

Published: 18 July 2014

Policies & Issues: Environment

The European engineering industries represented by Orgalime are fully committed to the responsible use and risk management of chemicals in their manufacturing processes, a proper supply chain management and the development of sustainable products, systems and technologies in overall respect of environmental and human health objectives. 

We particularly support the objectives of the EU´s chemicals policy acquis, including the REACH Regulation or the sector specific RoHS Directive, as well as the objectives pursued by several other critical pieces of EU legislation, such as the WEEE or Ecodesign Directives. 

For the purpose of ensuring timely and proper compliance with all EU legislation, however, our industry depends on regulatory predictability, stability and legal certainty. These requirements are at the same time key factors for stimulating industrial re-investment in Europe that will allow the manufacturing sector to continue adding value with a strong prospect of jobs and growth in Europe. 

In practice, however, our industries often experience the opposite, including in the area of chemicals policy: we face, for example, frequent inclusion of substances in the REACH candidate list, numerous reviews of sector specific legislation, insufficiently coordinated legislative or implementation activities on new and/or existing EU measures. Indeed, the engineering industries face more and more overlaps in the interface between REACH and RoHS that risk upsetting the overall consistency of the EU chemical legislation. This is not helpful for companies in terms of recovering the investment made in innovative products, nor for their global supply chain management, nor for their overall competitiveness. 

Therefore, Orgalime welcomes the Commission’s commitment to improve 'planning', 'predictability' and 'communication', as provided in the Roadmap on Substances of Very High Concern (SVHC) to 2020, which is aligned to the stated objective of the REACH Review.  We also welcome the Commission’s SVHC Roadmap, in conjunction with ECHA’s Implementation Plan as a first promising step towards a proper implementation of the REACH Review recommendations. Orgalime industries strongly support its core element, namely the proposal for carrying out the Risk Management Options (RMO) analysis on a regular basis. The SVHC Roadmap is in our view the occasion to implement the main principles of the wider EU Industrial Policy. A transparent, clear and predictable process should be ensured, while keeping the administrative burden, costs and workload to the minimum level necessary.

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