On May 12, 2015 the UK-based advocacy group for chemical safety CHEM Trust expressed their concerns regarding the simplification of the EU chemicals regulation REACH authorization applications. CHEM Trust highlights that the REACH chemical regulation system aims to provide a high level of protection to both the environment and the human population. A crucial part of the system is the authorization process. The European Commission (EC) has been looking at ways to make the authorization process less complex, and has just finished a consultation on simplifying the REACH chemicals regime concerning (i) uses of Annex XIV substances in low volume and (ii) uses of substances in legacy spare parts – those used to preserve the functionality of long lifetime durable articles.
The EC proposes that companies using low volumes of chemicals subject to authorization should provide less information and have fewer obligations. CHEM Trust opposes this change as it could potentially lead to increased use of Substances of Very High Concern (SVHCs) due to less incentive to develop and use safer alternatives. The EC also proposes to simplify procedures for authorization of SVHC use in legacy spare parts. CHEM Trust is concerned about the lack of clarity in the EC’s definition of key terms in their proposal. According to CHEM Trust, the definition for spare parts used in the context of derogations needs to be very narrow in order to prevent misuse, and there should also be no provision to allow new uses of SVHCs as part of this procedure.
CHEM Trust (May 12, 2015). “Simplification proposals for EU chemicals law REACH could increase chemical risks.”