The decision to grant authorisation to use problematic chemicals cannot be based solely on documentation provided by the intended user.
Companies that already invested heavily in order to avoid said chemicals are disfavoured and it’s not in line with REACH intentions.
Ahead of today’s CARACAL meeting in Brussels – where The Commission, Member States, ECHA and stakeholders gather to discuss REACH – The International Chemical Secretariat, ChemSec, have listed a number of issues within the REACH authorisation process that needs to be resolved.
The Commission is sending out a message that only the economic feasibility for the applicant is of importance when evaluating suitable alternatives, giving less weight to potential market implications for producers of alternatives. Furthermore, ChemSec is worried about applications where authorisation is being considered, even though there appears to be alternatives on the European market.
– We fear that granting these authorisations will cause an economic disadvantage to companies who have already invested substantial resources in substituting these SVHCs and gives an unclear message to companies on the legal intention that SVHCs should be substituted when possible, says Frida Hök, ChemSec Policy Advisor.
Today, emphasis tends to be placed on the interests of the applicants, and the process has weak incentives for third parties to provide opinions, even though they might possess key knowledge.
– ECHA committees need to actively seek out in-depth third party information, since the applicant is far more likely to contribute with extensive documentation supporting their case. Avoiding doing so might lead to green lighting the use of SVHCs although alternatives are available, Frida Hök concludes.