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Orgalime - REACH REVIEW - Orgalime Position Paper 20 March 2013


20 Mar 2013


Climate & Environment
Innovation & Enterprise
Trade & Society

In the context of REACH, Orgalime represents a major EU downstream user industry of chemical substances and preparations as well as EU producers and importers of final articles including many of their components for both, professional customers and private consumers. The EU engineering industries are clients of the chemical industry and supplier of capital goods to all other industry sectors, including the automotive, aerospace, chemical, food or textile industries as well as to the health and environment sectors.

Orgalime welcomes the Commission’s General Report on the REACH Regulation and its main recommendation to not change the main terms of the REACH Regulation in order to provide stability. We fully support this commitment towards legislative stability and predictability. In line with the EU industrial Policy, we believe that regulatory stability is necessary to allow the manufacturing sector to continue adding value with a strong prospect of jobs and growth.

In addition, unexpected impacts on the EU’s manufacturing industries have to be monitored carefully, as suggested in the REACH Review report. Indeed, we strongly believe that REACH implementation should neither result in unaffordable costs, nor negatively impact the competitiveness of the engineering industry.

We support the Commission’s approach to improve REACH through its implementation. Indeed, a better application of the REACH Regulation is needed, in particular in the following areas:

  • The coherence with sector specific legislation, such as the RoHS2 Directive.
  • Communication in the supply chain, including on nanomaterials, where a more effective flow of information is needed.
  • The functioning of the internal market, undermined by national legislation restricting the use of specific substances in some products.
  • The full harmonisation of REACH provisions, such as the implementation of the 0.1% threshold triggering communication and notification requirements (Articles 33 and 7.2 REACH).
  • The risk management procedures (authorisation and restriction procedures), where a more balanced approach and further consideration of socio-economic impacts on the EU manufacturing industries are necessary.
  • The inclusion of a Risk Management Options (RMO) analysis in the preparation of an Annex XV dossier, as a standard basis, and the involvement of stakeholders.

Proper implementation of REACH is indeed, in our view, crucial to the EU wide horizontal framework for chemical management. The horizontal Regulation should, in our view, set the principles and provide all relevant information on substances needed for a proper implementation of REACH itself but also of sector specific legislation, including the RoHS Directive and the various EU Waste, Waste Incineration or Industrial Emission Directives. In addition, we ask for a clear guidance on what risk management procedure (e.g.: REACH authorisation, REACH restriction, sector specific restriction via RoHS2, measures under the Waste Incineration or Industrial Emissions Directives) applies in what case.

Our industries remain available to provide input and information available in its role as downstream users and article manufacturer. We are committed to contribute to shape a successful, meaning truly consistent implementation of the EU chemical management policy especially both, REACH and RoHS, in our industry sector.


Mark Redgrove

Head of Communications



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