Orgalime position on REACH Consultation documents

Orgalime understands the intention of the Commission to address the current lack of information and knowledge about the extremely broad variety of different chemical substances for environmental, health and safety reasons.
However, we believe that the draft REACH proposal calls for in depth revision particularly along the following principles:

· Downstream user concerns must be assessed by undertaking a specific downstream user impact assessment in line with the better regulation principles.

· Market reality of companies that are acting in rapidly evolving market places where time to market is essential for business success must be taken into account.

· The definition of "downstream user" needs to be revised in order to address the risk of a substance as early as possible in the supply chain.

· The availability of substances must be ensured and sufficient time frames for finding substitutes for any substance that is called upon to be withdrawn must be provided.

· The multiplication of administrative work in the supply chain, in particular for SMEs, must absolutely be avoided. Simplicity is a must.

· Any future system should follow a priority system tackling substances with highest negative impacts on human health or the environment first and addressing the uses of concern based on risk rather than hazard.

· The disclosure of proprietary and confidential business data and internal company know how must be prevented.
Orgalime urges the Commission to seriously consider the impact of the proposed draft REACH regulation on all dimensions of sustainable development, i.e. environmental, social and economic, before advancing further with this proposal.