Industry’s view on the Roadmap on Substances of Very High Concern

The first industry experiences with the authorisation process are that this process is not just limited to manufacturers and/or importers.  Downstream users also clearly play a much more important role than ever anticipated.  It is in the authorisation process that the complexity of REACH is becoming increasingly evident across the entire supply chain. Experience so far with entering substances on the Candidate List and afterwards prioritising for Authorisation by inclusion in Annex XIV, have shown an underestimation of the complexity of the supply chain and demonstrate unforeseen impacts right down to the end of the supply chain, including recycling.

Therefore industry - indicated on the cover page - representing the interest of manufacturers, distributors, immediate downstream users and down to the ultimate end-users, do see the need to have a roadmap on Substances of Very High Concern.  This would be a first step towards a harmonised approach that is used by member states and the Commission to identify relevant potential substances for the Candidate List.  A transparent and predictable process is needed to avoid issues such as supply chain disruption, and would be consistent with one of the primary aims of REACH and of authorisation, which is to ensure the efficient functioning of the internal market.