Commission releases its General Report on REACH “REACH functions well and delivers on all objectives that at present can be assessed”
Everyone involved in REACH implementation (industry, Commission, ECHA, national authorities, NGOs) has come a long way since the adoption of REACH in 2006 and has gained increased experience, expertise and a better understanding of REACH provisions and their practical implications. Significantly more data on chemicals have become available. Industry has surmounted some difficult hurdles, and this has been a resource-consuming but valuable exercise, according to Guy Thiran, Director-General of Eurometaux. Our industry has indeed always considered REACH as a “responsible” investment.
Industry and the legislators need a stable system and full implementation before major changes are made. For instance, the registration requirements for the majority of SMEs will only be implemented by the 2013 and 2018 deadlines.
Guy Thiran adds that the non-ferrous metals sector believes that there is certainly room for improvement. However, this can and should be done within the existing framework of the Regulation itself, the guidance issued by ECHA, the tools developed for REACH implementation, and improved enforcement.
While some real practical experience has been gained with dossier evaluation and testing proposals, prioritisation of substances of very high concern (SVHC), restriction and harmonised classification, some of the processes are still fairly new, and more experience with implementation is needed, e. g. with:
- The best option to handle SVHC (restriction/authorisation or already existing legislation without additional measures): ensure fair and transparent decisions with input from industry, identifying the most adequate risk management option as early as possible in the process to increase the efficiency of authorisation/restriction procedures and improve the relevancy of the public consultation process. Substitution should only be aimed for where economically and technical viable
- Authorisation applications, in particular for SME, as many SMEs do not have sufficient resources and time to prepare and submit authorisation applications and to look for substitutes
- Substance evaluation
Further efforts are needed to address these pending questions. Additional legislative burdens that will bring about no real improvements in respect of the protection of human health and the environment need to be avoided.
Eurometaux is the Brussels-based association of the non-ferrous metals industry, representing the main EU and international metals producers, EU and international metal commodity groups and national metal federations. The industry covers base metals (Al, Cu, Pb, Ni, Zn, Sn), precious metals (Au, Ag, PGMs) and technical metals (e.g. Co, W, Cr, Mo, Mn), manufactured from both virgin and recycled raw materials.
For further information, please contact:
Eurometaux – European Association of Metals
Guy Thiran, Secretary-General
Tel. +32 2 775 63 10