The REACH Regulation which became operational on 1 June 2008 aims to ensure a high level of protection of human health and the environment for all chemical substances manufactured and imported into Europe. It is a complex and ambitious system that includes a rigorous procedure
for the entry on an authorised list of substances of very high concern. The 27 Member States are responsible for candidate substances for inclusion on this list. The process will lead to the evaluation of these substances based on scientific and socio-economic information and,
ultimately to their authorised use or substitution.

The process of identifying substances of very high concern (SVHC) and their uses started in June 2008 with the release of the “Proposed Substances for the Candidate List” that led to the publication of the first priority list of substances for authorisation. It is essential that this welldefined complex process takes place in a transparent and balanced way. The process is ongoing and needs to follow the scientific approach adopted by the Member States.

The signatory industries strongly feel that “the publication in March of an alternative list of substances of very high concern by the European Trade Union Confederation list issued in March is not contributing to the objective of sound and scientifically based assessment of substances as required by REACH, but rather it brings confusion.

The choice of authorisation criteria under the REACH process is the result of a long democratic
consensus process and any substance to be submitted for authorisation should be selected on the basis of these criteria. For example, Member States have decided not to retain CMR cat 3, skin sensitizers and neurotoxins, or IARC group 2b for the list of SVHC (substances of very high
concern). Allowing the expansion of the prioritisation scheme by any single organisation, using their own set of criteria, excludes others from the process and detracts from scientific discussions. The REACH process was designed and agreed to complement and enrich existing
European risk management or risk reduction legislation already in place and inappropriate expansion thwarts the democratic process embedded in REACH. More scientific arguments can be found in the appendix.

Acknowledging their responsibility in terms of burden of proof, the European cement, glass, minerals and non-ferrous metals industries are actively preparing to meet their obligations under REACH and call on respecting the integrity of the agreed upon process.

E-mail : eurometaux@eurometaux.be [1]
E-mail: secretariat@ima-europe.eu [2]
E-mail: info@cpivglass.be [3] E-mail : technical@cembureau.eu [4]