Orgalime key messages on REACH

Orgalime recommends to the European institutions to shape the REACH proposal in a way that would fully mirror the different roles and responsibilities of the individual actors in the supply chain. From our second level downstream user perspective we highlight the following key areas:

- Harmonisation at both, global and European level

- Introduction of clear, simple, broad exposure and application categories instead of the concept of "identified use"

- The availability of substances is a core element of innovation and competitiveness of European engineering industries

- Information passed on in the supply chain should be harmonised, simple, straightforward and operational

- Substances in articles, waste and basic raw materials for the metal industry should not fall under REACH

- REACH should not overlap with specific product related legislation for engineering products nor with other legislation, such as occupational health and safety or specific environmental legislation

- REACH should establish a risk based priority system