Input to the review study of the scope of REACH & other EU Legislation to assess overlaps & gaps

Published: 27 July 2010

Policies & Issues: Environment

Orgalime appreciates the possibility to contribute with its comments to the study on scope of REACH and other relevant EU legislation with a view to assessing possible overlaps and gaps.

The EU’s horizontal chemicals law, the REACH Regulation based on article 95, aims at fully harmonising the EU’s framework for the management of chemicals, including substance registration, evaluation, restriction and authorisation requirements and uses of substances in the EU.  However, despite the adoption of the REACH Regulation in 2006, several pieces of other EU legislation affecting Orgalime industries continue to include and/or introduce new provisions related to chemical substances, which often create overlaps, legal uncertainty and unnecessary duplication of law, administrative burden and costs.

The main consequence of this is that cohesion and consistency are not fully secured for European engineering industries, while at the same time unclear legal requirements also weaken environmental objectives and proper enforcement of law.

Related Position Papers

Environment: Wastewater matters too: Orgalim’s recommendations for the revision of the Urban Waste Water Treatment Directive [22 May 2020]

Environment: Think Blue: Orgalim recommendations for the improvement of the Water Framework Directive [22 May 2020]

Environment: Response to Commission circular economy roadmap consultation [20 January 2020]

Environment: EU-wide uniform conditions for the proper quality treatment of WEEE: A call for Implementing Acts to lay down minimum quality WEEE treatment standards in strict accordance with the European standards [12 December 2019]

Environment: Evaluation of Directive 2011/65/EU (“RoHS”): Improving implementation in a Circular Economy context [6 December 2019]

Environment: Orgalim response to the public consultation on the RoHS evaluation [6 December 2019]

Environment: The European technology industries’ priorities for the sustainable use and management of water in Europe [14 November 2019]

Environment: Orgalim's response to a public consultation on sustainability requirements for batteries [27 August 2019]

Waste policy: Joint industry comments on modulating producers’ financial contributions for Waste Electrical and Electronic Equipment [26 July 2019]