ChemSec has joint WWF and other NGOs in a letter to Antonio Tajani and Janez Potocnik, respectively new EU Commissioner for Industry and Entrepreneurship and new EU Commissioner for the Environment, in order to express concern regarding the delayed progress of REACH implementation.

The main issues of concern include the Commission proposal on the criteria for the inclusion of persistent, bioaccumulative and toxic ((PBT) chemicals, the lack of progress on the REACH Candidate List and the delay in starting the Authorisation process. On 25 March 2010 the two Commissioners will visit the European Chemicals Agency in Helsinki.

Passages from the joint NGO letter:

First, on the important comitology decision on the PBT criteria (REACH Annex XIII), we would like to refer to our detailed letter to the Commission on this issue from 5 December 2008. In our view, the Commission has so far ignored expert advice from Member States, scientists and NGOs to ensure that all relevant information is considered in the PBT/vPvB identification. Instead, the Commission's proposal from 2008 does nothing to change the criteria, which rely on a set of narrow laboratory test methods and fail to address the problem of increasing contamination of people and wildlife with persistent, bioaccumulative and toxic chemicals.

Second, we continue to deplore the lack of progress on the REACH candidate list. More than two years after entry into force, the candidate list only contains 29 officially recognised substances of very high concern compared to 478 substances identified by a group of Member States as meeting the official REACH criteria and the 356 substances on the NGO SIN List 1.1 ("Substitute it Now!)". At this slow pace, the listing of substances of very high concern alone will take decades, not to mention the subsequent implementation of authorisations and restrictions. This would perpetuate continued chemical exposure for wildlife and people and negate the incentive for innovation and substitution. We urge you to dedicate more resources to speed up the substitution of substances of very high concern, including hormone disrupting substances.

Third, we remain concerned about the delay in starting the authorisation procedure. Since June 2009, the Commission has not taken action on the seven prioritised substances of very high concern recommended by ECHA. This is, again, simply unacceptable. We urge the Commission to proceed with the formal comitology adoption procedure without any further delay. REACH aims to ensure that the risks from substances of very high concern are properly controlled and that suitable alternative substances or technologies progressively replace them. Therefore, in all cases, substitution plans should be a key element together with the analysis of alternatives since authorizations will be subject to time-limited review and are subject to specific conditions.

Joint NGO letter to EU Commissioners