The recommendations sent to the European Chemical Agency (ECHA) by 13 NGOs intend to assure that Substances of Very High Concern (SVHCs) for which safer alternatives exist do not continue to be used. The recommendations stress that not only the applicant but also third parties should be responsible for providing information on safer alternatives. The recommendations ask for third parties to participate at different levels in the European Registration, Evaluation, Authorisation and Restriction of Chemical substances (REACH) authorization process. Applications should furthermore be public, restricting confidentiality claims to the farthest extent possible. The recommendations ask for third party participation to be encouraged by providing a web site and a help desk with application information and to make this information available early on in order to allow third parties to prepare their submission of information. Third parties including academia, NGOs and user’s associations shall be contacted directly. Finally, the NGOs support the establishment of an alternatives competition for third parties in order to accelerate the creation of viable alternatives for SVHCs.

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