Advancing REACH

Erklärung des Begriffs REACH: Europäische Chemikalienverordnung zur Registrierung, Bewertung, Zulassung und Beschränkung chemischer StoffeClick to enlarge
REACH stands for registration, evaluation, authorisation and restriction of chemicals
Source: Umweltbundesamt

The following reports are the result of the project “Advancing REACH”, which is funded within the research plan of the BMU. The project analyses various aspects of the REACH Regulation and its implementation and develops possible improvements, including possible amendments to the text of the Regulation and its annexes.

Aim and object of the research project

Together with other projects, this research project is intended to support the work of the German authorities (such as the Federal Environment Agency, the Federal Institute for Risk Assessment, the Federal Institute for Occupational Safety and Health) and the  Federal Ministry for the Environment, Nature Conservation and Nuclear Safety on the possible further development of the ⁠REACH⁠ Regulation. In addition to various analyses, workshops will be organized and support provided for the REACH Congress 2018. Details can be found in the individual work packages.

As far as proposals for the improvement of the REACH Regulation or its implementation are to be developed, a distinction should be made between those that require an amendment of the legal text of the Regulation (separated according to article part and annexes) and those that can be achieved by a change in practice or guidelines.

 

WP 1 Analysis of documents supporting the REACH-Review 2018
Based on a document analysis, the evaluation of the state of implementation as well as the improvement proposals for the REACH review 2017/2018 have been identified and compiled. Several studies commissioned by the EU Commission, reports by ECHA, studies by NGOs as well as documents published by industry actors and member states were analysed.
Link: UBA Texte 93/2018

AP 2 Benefits & Costs of REACH
The objective of this work package was to review the existing literature to determine the current level of knowledge of the benefits and costs associated with REACH.  The primary focus was on the identification of the gaps in the assessment of benefits, as multiple studies have already concentrated on the costs caused by the implementation of the REACH Regulation.
The assessment framework and the reports reviewed in this study are summarized. The current state of knowledge and any gaps in the benefit and cost data/information are broken down by each single component of REACH regulation, namely Registration, Information in the Supply Chain, Evaluation, Authorisation, Restriction, Guidance, Inspection and Enforcement. Conclusions are drawn.

WP 3 REACH Congress 2018
In December 2018, the German Ministry for the Environment, Nature Conservation and Nuclear Safety, in cooperation with the Federal Office for Chemicals, hosted the fourth national REACH congress. With a view to the 2nd review of the REACH regulation, the state of implementing the registration, evaluation and risk management procedures was presented from the perspective of different REACH actors and discussed. The congress ended with an outlook to the further REACH implementation.  
Link: UBA Dokumentation 1/2019; https://www.oekopol.de/wp-content/uploads/REACH-Weiterentwicklung_Online-Befragung.pdf

WP 4 Analysis of SEAs in the context of SEAC’s work
The aim of the work package is to identify the key elements that drive SEAC conclusions as well as those that are rarely taken into account. Additionally, the work package highlights potential systemic/structural deficits of SEAs and Analyses of Alternatives (AoAs), in the context of Applications for Authorisation (AfAs) and the respective SEAC opinions.

WP 5.1 Restrictions
The aim of this work package was to come up with proposals to make the procedure of restriction more simple, efficient and faster. Proposals are based on an analysis of current implementation and shall be brought in discussions at EU level. The focus is on the workload for authorities, the duration oft he procedure and the role oft he committees.

WP 5.2 Substance Evaluation
The aim of this work package was to come up with proposals to improve substance evaluations. Proposals are based on an analysis oft he REACH legal text and the current implementation and shall be brought in discussions at EU level.

WP 5.3 Dossier Evaluation
The aim of this work package is to analyse whether and how the quality of registration dossiers can be improved (efficiently) by dossier evaluations or other mechanisms. This includes an analysis of of potential mechanisms for sanctioning or motivating registrants. The procedures of dossier evaluations and follow-up measures were analysed on the basis of available dossiers as well as expert interviews in order to conclude on measured to improve dossier quality.

WP 5.4 Assessment of the Authorisation process under REACH
This study analyses the authorisation process under REACH, including the identification of a substance as of very high concern prior to candidate listing, prioritisation for an uptake onto Annex XIV, application for authorisations and their processing until a decision is taken, as well as further supporting instruments such as regulatory management option analyses and screening processes.
Link: UBA Texte 41/2021

WP 5.5 Consultation processes
coming soon

WP 5.6
coming soon

WP 5.7 ECHAs Board of Appeal
coming soon

WP 6 REACH and sustainable chemistry
The European chemicals regulation REACH is intended to contribute to a more sustainable chemistry. A current UBA report provides a systematic analysis on the relations between main elements of REACH (e.g. Registration or Information in the supply chain) and main elements of sustainable chemistry (e.g. substitution of hazardous substances or corporate social responsibility of companies).
Link: UBA Texte 147/2020

AP 7 Financing options for ECHA
The report considers the activities carried out by the European Chemicals Agency (ECHA) to implement REACH and ⁠CLP⁠ to date, the expenditure needed to sustain this work and the funding structure of the Agency as background to the consideration of how new finance concepts could be adopted to finance ECHA’s activities after 2018 in the short term, medium term and longer term.
Link: UBA Texte 118/2019

WP 8 Substances in Articles
The study analyses, under the perspective of the aims of the REACH Regulation and the requirements formulated in the context of the “circular economy package”, the current legal framework of instruments governing the risk management and related notification and communication obligations concerning “substances in articles” (SiA).

WP 9 Precautionary Principle
coming soon

WP 10 REACH and substitution
This study analyses the support of the so-called substitution, which is the use of less hazardous alternatives for substances of concern, by instruments of the REACH regulations and elaborates concrete recommendations.

WP 11 Workshop on SVHC in articles
coming soon
Link: Workshop Dokumentation: https://oekopol.de/themen/chemikalienpolitik/reach-weiterentwicklung/

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 REACH  European chemicals legislation