Comments on the revision of REACH Regulation to help achieve a toxic-free environment

The Stockholm University Baltic Sea Centre's comments on the European Commission’s Chemicals legislation – revision of REACH Regulation to help achieve a toxic-free environment

May 31, 2021

The reply concerns this open consultation by the EU Commission.

The answer has been prepared by: 
Marlene Ågerstrand, Assistant Professor, Department of Environmental Science, Stockholm University 
Marie Löf, PhD, Advocacy and Analysis Officer, Stockholm University Baltic Sea Centre.

We welcome a careful and limited revision of the EU legislation on registration, evaluation, authorisation and restriction of chemicals, REACH, to better protect humans and the environment against hazardous chemicals and promote a sustainable use of chemicals. It is key, however, that a revision does not lead to a weakened chemicals regulation, in any aspect. A targeted opening of the REACH legislation is therefore needed. 

 

Section "Problem the initiative aims to tackle": 

In general, we agree with the identification of the problems described in the roadmap, which the initiative aims to tackle. However, under the point ‘The evaluation of registration dossiers and substances is too complex and insufficient.’ we find the phrasing ’too complex’ somewhat worrying. It is very important that rationalisations and simplifications of the registration process, incl. the compliance check and substance evaluation, does not lead to a deterioration in the quality of the registration dossiers, or their control, as their completeness and accuracy is a fundament for the risk assessment.  

 

Section "Objectives and policy options": 

Under this section we have identified complementary measures that should be included to improve risk assessment of chemicals:

  • Increasing the transparency of data: Full transparency should be the general rule for the whole chain of events from generation of information, via reporting of data, to hazard and risk assessment. The current developments in the food law are very welcome and should be expanded to all chemicals.

    In a system where manufacturers are responsible for assessing their own products sufficient resources to control the quality of this work must be secured. The overall aim must be full legal compliance.
     
  • Making use of academic studies: change the requirements to also include academic studies, if available, in hazard and risk assessment, as a complement to the toxicity studies commissioned by the chemical industry. Increasing the use of academic studies is also expressed in the Chemicals Strategy for Sustainability.
 

Reforming the authorisation process

Under 'Reforming the authorisation process' supplement the current wording with text within quotation marks: 

  • Reforming the authorisation process: Options include clarifications and simplifications of the current provisions, national authorisation for smaller applications, removing the authorisation title from REACH, integrating the REACH authorisation and restriction systems into one and improving the interface with other pieces of legislation (complementing actions under the one-substance one-assessment action under the Chemicals Strategy), ‘and the concept of essential use should be aligned with the authorisation process’.

We strongly support the ambition in the Chemicals Strategy for Sustainability to ’introduce endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern’ within REACH restriction processes. 

For relevant research and findings that support our ideas, please see the links below:

For more information about the need for grouping and mixture risk assessment in European chemicals legislation, please read here: 

Policy brief - Time for smarter and safer chemical management

and here: Future chemical risk management, SOU 2019:45.

For more information about the need for increased transparency in REACH, please read here:

Policy brief - European chemicals reglation needs more transparency

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