Nine EU member states, trade associations, and non-governmental organizations have supported the criteria defined by Germany for mobile substances. But disagreement still exists on how to implement the criteria in legislation.
The report containing the criteria was presented at the CARACAL meeting in July. The German Federal Environmental Agency (UBA) has published REACH: Improvement of guidance and methods for the identification and assessment of PMT/vPvM substances on its Web site.
Meanwhile, several national agencies, associations, and organizations have reacted to the German proposal. The German Federal Institute for Occupational Safety and Health has collated the reactions in a document. The following institutions offered comments:
- National agencies in Austria, Spain, Finland, France, Ireland, the Netherlands, Norway, Sweden, and the United Kingdom
- Five industry associations
- European Environmental Bureau as an umbrella association of more than 140 environmental organizations
- Joint Research Center (JRC) as the scientific service of the EU Commission
- EurEau, the union of national water service operators
- Organization for Economic Co-operation and Development (OECD)
All groups cited the need for risk management measures for PMTs (Persistent, Mobile and Toxic) and vPvMs (very Persistent, very Mobile). These substances should also be classified as substances of very high concern (SVHCs). For example, some countries want to anchor the identification of PMTs and vPvMs in Article 14, Section 4 of REACH. Other prefer including the criteria formally in Article 57 (the substances to be included in Annex XIV) or Annex XIII. Individual institutions made other suggestions.
Research into scientific literature preceded the determination of the mobility criteria: Some 25 studies were evaluated between 2000 and 2018. In the studies, scientists identified 333 chemicals: 246 in drinking water and 187 in ground water. Some 142 of these chemicals are substances that were registered under REACH (as of May 2017). See page 15 of the UBA document.
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