One of the priority areas of UBA's work as concerns REACH is the identification of Substances of Very High Concern. "The process is highly complex in terms of science and organisation. Some say it is too slow-going, but the list of Substances of Very High Concern has now grown to 155 and is likely to reach 161 by mid-December. The work done by the Federal Environment Agency has produced 18 candidate chemicals for the list", said Ms Krautzberger. The authorisation requirement under REACH already applies to several of the Substances of Very High Concern, including four phthalates, which are on the list due to their teratogenic effect.
Being subject to authorisation means that the chemical may only be used if the application in question has been explicitly permitted by the EU Commission as a result of an authorisation procedure which involves all the Member States. Enterprises which want to continue to use chemicals subject to authorisation must either provide proof of their safe use or demonstrate that the application for which it seeks authorisation is of benefit to society as a whole. There are review dates scheduled for every authorisation granted, because all chemicals subject to authorisation are to be replaced in the long term, either by suitable alternative chemicals or by alternative technologies in so far as it is economically and technically viable.
It is small and medium-sized enterprises (SME) in particular which are calling for support from public authorities in the authorisation procedure. "To grant enterprises more planning certainty, the German authorities will in future inform SME early on about their regulatory work planning. In return, SME will submit practical information about how chemicals are used, which is important for the authorities' determination of appropriate regulatory instruments. The overall aim is to make the authorisation procedure more transparent and to enable the applicant to better estimate its chances of obtaining authorisation", said Federal Environment Minister Barbara Hendricks. A letter from several Member States addressed to the new European Commission and signed by Minister Hendricks calls for ambitious further development of chemicals policy and also addressed this particular issue.
One overarching aim of REACH is to create transparency, also on Substances of Very High Concern which may be contained in everyday goods such as textiles, toys or household appliances. The REACH Regulation enables consumers to obtain information about whether products contain these chemicals. UBA has simplified the online query procedure for all stakeholders – queries can be submitted by clicking on http://www.reach-info.de. The product code and one's personal contact information are all it takes to complete a query. Merchants, manufacturers and importers must respond within 45 days and at no cost as to whether there are any Substances of Very High Concern in the product and which are on the Candidate List – irrespective of a potential purchase of the product.