In the REACH legislation, the chemical industry is responsible for assessing risks for human health and the environment for chemicals registered on the European market. The registration dossiers are sent to the European Chemicals Agency (ECHA) where only a small percentage per tonnage band are to be checked for compliance with the REACH legislation. Recently ECHA announced an increase from 5% to 20%. Consequently, the majority of the registration dossiers will not be checked. According to the European Commission’s own investigations, more than half of the dossiers that were checked turned out to be in-compliant.



We use in our daily lives a wide range of chemical-intensive products such as construction materials, textiles, cars, electronics and toys – and the use of chemicals in society is increasing every year. This requires an improved ability to understand, identify and manage potential chemical risks to human health and the environment.
In 2007, the European chemicals legislation REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) was adopted to ensure that risks with chemicals are adequately controlled. However, the processes for identifying and taking appropriate regulatory measures against potentially harmful chemicals are still slow in relation to the current production rate of chemicals put on the European market. 
To meet the challenges of our time regarding chemicals in everyday life, the structures for control and gathering of chemical information under the legislation must be improved. One action that could increase the precondition for using REACH to identify chemicals of concern for human health and the environment is to introduce significantly more transparency in the registration process.


To the European Commission: 

  • Investigate and suggest changes in the REACH legislation that further increase the transparency.
  • Investigate the possible negative consequences of conflicts of interest in the REACH registration process, and consider the option of having an independent third party performing chemical risk assessments.
  • Increase the number of dossiers that ECHA has to review, to allow for an increased quality in the control of the chemical risk assessments.

To the European Chemicals Agency:

  • Further explore how dissemination of risk assessments and toxicity studies can be enhanced within the current REACH legislation.
  • Implement and enforce a common method with clear criteria and guidance for evaluating toxicity studies, as well as a template for transparent reporting of assessments.

To the chemical industry:

  • Support transparency initiatives and make the toxicity studies used for concluding on chemical risks fully available for independent scrutiny.

Read and download the Policy Brief (pdf):

Policy brief REACH (348 Kb)

Read an interview with author Marlene Ågerstrand at the web magazine Baltic Eye:

Researchers require increased transparency within REACH