The European Chemical Industry Council (CEFIC) and Concawe, the consortium of leading European oil companies, have criticized the plans of the EU Commission to modify Annexes VI–XI of REACH. The Annexes cover the data requirements for chemicals. The changes to the Annexes are part of an EU action plan to improve data quality and, as a result, the quality of REACH registration dossiers.
The objection of the groups is that the registration dossiers that have been legally compliant thus far would suddenly all become inadequate, forcing companies to expend effort to update them. In its position paper, Concawe suggested that the new requirements should apply only to new dossiers being submitted. It also called for the EU to consider complex chemicals when modifying the Annexes, specifically those with unknown or variable composition, complex reaction products, or biological materials (Substances of Unknown or Variable Composition, UVCBs). CEFIC also published a statement characterizing the actions of the ECHA and EU as contradictory. On the one hand, they require companies to check and improve their existing REACH dossiers systematically. On the other hand, they complicate this very process by leaving companies unclear about the new requirements.
The planned modifications of the REACH Annexes are part of action plan to evaluate registration dossiers that was initiated by the EU and ECHA. The action plan was published in June and describes 15 measures to improve the quality of registration dossiers.
The German Chemical Industry Association (VCI) provides an overview of the topic in its Data and Facts – REACH Implementation (German only).
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