REACH-Dossier-Aktualisierung: EU-Staaten schlagen Durchführungsverordnung vor

Die drei EU-Mitgliedstaaten Frankreich, Niederlande und Ungarn sowie Norwegen setzen sich für obligatorische regelmäßige Updates der REACH-Registrierungsdossiers ein und machen sich für eine Durchführungsverordnung stark. Ihre Position formulierten sie in gesonderten Papieren, die sie im Anschluss an eine Diskussion über fünf der 16 REACH-Review-Maßnahmen auf der Caracal-Sitzung im Juni einreichten. Ihr Argument: Mit der Maßnahme würden keine neuen Verpflichtungen festgelegt, sondern lediglich bestehende geklärt. Im Kern geht es darum, die in Artikel 22 genannten Bedingungen klarzustellen.

Dort heißt es, der Registrant sei nach der Registrierung dafür verantwortlich, diese „aus eigener Initiative“ und „unverzüglich“ anhand der einschlägigen neuen Informationen zu aktualisieren und diese der Agentur zu übermitteln. Allerdings lässt der Wortlaut offensichtlich Spielraum für Interpretationen zu, sodass viele Unternehmen einer Aktualisierung erst nach ausdrücklicher Aufforderung der ECHA nachkommen.

Mit einem Durchführungsgesetz, so das Argument der Franzosen, seien Unternehmen gezwungen, ihre Registrierungen von Zeit zu Zeit zu überprüfen. Eine regelmäßige Überprüfung sollten Unternehmen in IUCLID aber auch in solchen Fällen dokumentieren können, die keine Aktualisierung des Dossiers erfordern. Ebenso wie Frankreich halten auch die anderen drei Staaten eine Durchführungsverordnung für die pragmatischste Lösung.

Mit ihrem Anliegen sind die vier Länder jedoch nicht allein. So wollen auch die beiden Branchenverbände, die Downstream Users of Chemicals Coordination Group (Ducc) und Eurometaux, verbindlichere Vorgaben nach Artikel 22. Eurometaux beispielsweise fordert einen „klaren und systematischen Prozess“ für die Aktualisierung der Dossiers. Dazu bringt Eurometaux eine Checkliste ins Spiel, die Unternehmen in Konsortien Orientierung bieten soll bei der Frage, in welchen Fällen eine Datenaktualisierung notwendig ist. Beispiele für Checkpunkte wären etwa:

  •  Stoffidentitätsprofile (bei neuen Registranten);
  •  Gefahrenprofile/Einstufungen für Mensch und Umwelt; und
  • neue wissenschaftliche Erkenntnisse, die zu Änderungen bei der Einstufung, in Sicherheitsdatenblättern, im Stoffsicherheitsbericht, etc führen.

Auch Echa-Chef Bjorn Hansen hat Artikel 22 als die Schwachstelle erkannt. In seiner Rede auf der REACH-Review-Konferenz im Juni räumte er ein, dass REACH im Hinblick auf die Aktualisierung der Dossiers nicht zwingend genug ist. Bereits in einem von der Agentur in Auftrag gegebenen und im September 2017 veröffentlichten Bericht heißt es: Neue Regulierungsmaßnahmen müssen sicherstellen, dass die Aktualisierungen in festen regelmäßigen Abständen, beispielsweise alle drei Jahre, erfolgen.

Benötigen Sie Unterstützung bei der Registrierung eines Stoffes? Melden Sie sich gerne unter reach@kft.de.

 

 

 

 

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