Orgalime position on REACH Consultation documents

Published: 9 July 2003

Policies & Issues: Environment

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must be ensured and sufficient time frames for finding substitutes for any substance that is called upon to be withdrawn must be provided.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

Related Position Papers

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]

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

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

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

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

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

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

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