REACH Revision: Industry Associations Call for Greater Transparency in the Regulation of Substances

The REACH revision has been on hold for years. The EU Commission now intends to present a proposal for simplification of the regulation by the end of the year. The proposal prompted industry stakeholders once again to set out their demands emphatically in a letter to the EU. Despite the simplifications that the EU announced, the authors fear further bureaucratic hurdles for companies.

Criticism of Expanded Risk Management

One item that the associations criticize is the extension of risk management to certain hazards that go beyond carcinogenic, mutagenic, and reprotoxic substances – such as the persistence and mobility of substances in the environment. This proposal would inevitably restrict substances that are safe to use in small quantities or under strictly controlled conditions.

Criticism of the Mixture Assessment Factor (MAF)

The associations also oppose including a mixture assessment factor in REACH. The MAF would lead to a considerable increase in bureaucratic involvement. They also claim that assessing substances based on this factor is scientifically questionable, given the limited combination effects of chemicals. A blanket application would therefore also affect substances without combination effects and restrict their use.

Criticism of Mandatory Reporting for Polymers

The authors also oppose a general registration requirement for polymers. Instead, they advocate using existing regulatory options, such as REACH restrictions, approvals, or the Single-Use Plastics Directive.

The Advantages of a Road Map

The letter states that the EU should provide companies with a clearly defined regulatory road map that sets out which substances are to be evaluated and when. Such a road map would enable authorities to consider information such as use, exposure, tonnage, and the availability of alternatives in their assessment and then regulate substances more appropriately. For a substance that is only of concern for health and safety at work, for example, occupational safety legislation, rather than REACH, would be responsible. This approach would also reduce the burden on the ECHA and provide transparency for companies.

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