German Advisory Council on the Environment

REACH
EU Commission on the Right Track – Alternative Proposals Barely Workable

Date 2005.10.27

The German Advisory Council on the Environment (SRU) sees the proposed reform of EU chemicals policy (REACH) as a project of outstanding importance. REACH (Registration, Evaluation and Authorisation of Chemicals) is designed to provide adequate and effective protection for people and the environment. This means closing existing knowledge gaps, developing appropriate safety models and setting up an authorisation process for particularly hazardous substances. An SRU Statement issued today presents a systematic comparison of the key proposals for a workable and targeted registration process designed to detect risk substances. Given the range of substances to be assessed, it is vital that the process begins with particularly hazardous substances.

Based on the findings of its comparative study, the German Advisory Council on the Environment expressly calls for the approach set out in the EU Commission's 2003 proposal to be maintained. Compared with alternative proposals, it has a number of key advantages:

  • A clear order of priority for substance assessment in accordance with well-defined registration criteria
  • Binding deadlines coupled with the threat of sanctions and thus certainty as regards enforcement for businesses and public authorities

Clear assignment of the burden of proof to businesses: exceptions may be made regarding provision of information according to production volume, but are subject to justification. The Commission proposal thus also provides for a risk-based testing strategy.

Rather than providing for chemical safety at a comparable level to that allowed by the Commission's proposal, the latest alternative proposals – particularly those of the European Parliament Committee on Internal Market and Consumer Protection – will lead to burgeoning red tape. The German Advisory Council on the Environment also has concerns regarding the workability of the alternative proposals because they would confront the new European Chemicals Agency with tens of thousands of controversial case decisions. The Council thus recommends approving the Commission's proposal, albeit with a number of improvements at detail level.

These include:

  • Enhanced quality assurance in the information provided by producers and importers
  • A more informative and more comprehensive set of basic data.
  • More precise wording of substance exemption criteria.
  • More flexible priority setting for chemicals registration

The full statement paper is online available at www.umweltrat.de
For further background information, please contact the Council's Secretary General, Dr. Christian Hey at +49 (0)30 26 36 96 110.

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