Is a Registration Obligation for Substances in Imported Products Legal?

A legal opinion issued by the German Environmental Protection Agency (Umweltbundesamt) states that a registration obligation for substances in imported products such as clothing, sports gear, and toys would be compatible with the legal demands of the World Trade Organization (WTO). Such an obligation would better enable the EU to protect human beings and the environment against substances of very high concern that are used in these products. So far, substances in imported products are exempted from the authorisation requirement.

In their legal opinion, the authors also call for a mandatory, standard communications format that manufacturers would have to use not only to list the name of the substance of very high concern contained in the product, but also its concentration; its total volume; and information on its hazardous properties, safe use, and safe disposal. The authors provide a sample of what that kind of standard communications format would look on page 153 of the legal opinion. You can find additional tips and suggestions here.

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