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This is why YOU should respond to the REACH revision public consultation

Policy

This is why YOU should respond to the REACH revision public consultation

Published on 05 Apr 2022

You might not be aware of it, but this is the moment when everything might change; you have a once-in-a-lifetime opportunity to make a difference right now. REACH, the European chemical legislation is about to be revised, and your opinion is needed. Until the 15th of April, it is possible to have your say, by simply following this link and completing the form.

Long-time ChemSec readers know that REACH doesn’t work as intended. There are still too many hazardous substances present in everyday products, creating a threat to the health and wellbeing of ordinary people and our environment.

The process of substituting and phasing out hazardous substances has also been too slow, which is now widely recognized.

There is a flagrant lack of information in supply chains, making it more difficult for individuals and companies to vote with their feet and move away from hazardous substances.

“The more reasonable voices heard in this process, the more likely it is that the revision will turn out good”

This is the first major revision of REACH since its implementation in 2005, and therefore a once-in-a-lifetime opportunity to change European chemical legislation. You might think that this is too big, that your voice will be muzzled by the noise in the Brussels bureaucracy bubble, but that is not true. The more reasonable voices heard in this process, the more likely it is that the revision will turn out good.

Here are three areas that you might want to influence:

1. Better information

The so-called registration dossiers largely lack vital information about the toxicity of the chemical in question, as well as where the chemical is used – even if required by law. This lack of information causes problems throughout the entire supply chain.

Moreover, both downstream users and investors have insufficient information about chemicals that they buy or invest in, preventing them from voting with their feet. ChemSec has previously highlighted this topic from an investor’s perspective. This is something that urgently needs to be addressed.

2. Efficient mechanisms for substitution

According to the Commission, substitution of the most harmful substances has not occurred at the expected pace under previous regulations. This has led to significant missed market opportunities for producers of safer alternatives (which is described in this ChemSec report), and will ultimately also create trouble further down the value chain, as frontrunner companies will not be provided with the chemicals they demand.

The revision of REACH gives a good opportunity to create mechanisms for substitution – systems that incentivize the chemical industry to move away from hazardous chemicals.

3. Efficient enforcement

There are currently different ways to circumvent legislation and continue to produce hazardous chemicals (as we have described in this satirical guide) that must be addressed. The lack of enforcement is creating an uneven playing field in the European market that is bad for all of us. Loopholes must be closed, more resources must be used to find those that break the law, and there must be harsher punishments – not just a slap on the wrist.

Need inspiration? Here you go!

If you find it difficult to come up with good ideas for the consultation, perhaps you can find some inspiration from ChemSec’s opinions on the topic. Read our contribution and input here:

Summary: ChemSec’s Contribution to the Public Consultation REACH revision (pdf)

Full: ChemSec’s Contribution to the Public Consultation REACH revision (pdf)

If the revision of REACH is successful, it holds the potential to greatly strengthen the protection of human health and our environment, as well as improving the conditions on the European market. It is in the interest of all – us and you – that this happens.

So, don’t miss this once-in-a-lifetime opportunity to make a difference!