Comments on draft ECHA Guidance on Requirements for Substances in Articles (Version 4.0)

Published: 13 April 2017

Policies & Issues: Environment

As the European Chemicals Agency (ECHA) finalises the update of the Guidance on Requirements for Substances in Articles, Orgalime has published a position paper reiterating the points that we believe will support workable and proportionate implementation of article 33 of the REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) Regulation.

As a member of ECHA’s Partner Experts Group and as the umbrella organisation of the European engineering industries, Orgalime has commented thoroughly on the previous draft guidance. To read the key points we wish to emphasise in advance of the guide’s publication, download our new position paper here.

Related Position Papers

Eunomia study in support of developing Guidance for Extended Producer Responsibility (EPR) Schemes: Comments on modulation of producers’ financial contributions [12/3/2019]

Feedback on the usability of the taxonomy - Orgalim response [25/2/2019]

Orgalim response: Consultation by Technical Expert Group on Sustainable Finance [25/2/2019]

Orgalime response to consultation on RoHS Substance Review Methodology [21/12/2018]

Comments on Product and Organisational Environment Footprint methodologies (PEF/OEF) [19/12/2018]

Circular Economy: Resolving the interface between EU waste, product and chemicals policy [29/10/2018]

Strategy on long-term EU Greenhouse Gas (GHG) emissions reduction: Turning challenges into opportunities - The contribution of the European technology industries [10/10/2018]

The EU Plastics Strategy: An Opportunity to Build a Competitive European Market for Secondary Raw Materials [10/6/2018]

Roadmap for EU product policy: creating a market for circularity [4/6/2018]