Open Access Discussion

Five years REACH – lessons learned and first experiences. I. an authorities' view

Christoph Schulte1*, Lars Tietjen1, Ann Bambauer2 and Andreas Fleischer2

Author Affiliations

1 Federal Environment Agency, Wörlitzer Platz 1, 06844, Dessau-Roßlau, Germany

2 Federal Institute for Occupational Safety and Health, Friedrich-Henkel-Weg 1-25, 44149, Dortmund, Germany

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Environmental Sciences Europe 2012, 24:31  doi:10.1186/2190-4715-24-31

Published: 20 October 2012

Abstract

Background

Five years after entering into force, all the instruments of the REACH Regulation are active.

Results and conclusions

The first five years of REACH are characterised by a good cooperation between the European Chemicals Agency ECHA and the Member States authorities. As expected, much information for the most important chemicals on the European market was made available by the responsible registrant. However, the access to information for the public, researchers and downstream users needs to be expanded.

Most of the registrations submitted to ECHA didn’t fulfil the expectations of the authorities with regard to transparency and quality. To assure a safe use of chemicals, manufacturers, importers and downstream users need to take over the responsibility for compliance and quality of the registration dossiers and the assessments including risk management. For the upcoming second registration deadline, registrants are requested to submit fully compliant dossiers. For many dossiers already submitted updating is required.

By September 2012, 84 Substances of very high concern are included in the candidate list. For 54 substances, proposals are submitted by the Member States and ECHA. Hence, the objective of the European Commission, to have 136 substances of very high concern included in the candidate list by end 2012 might be reached.

With regard to regulatory activities, identifying of at least PBT and vPvB substances is challenging due to missing information. In addition to that, the interface between restrictions and authorisations needs to be improved to include SVHC in (imported) articles in the authorisation regime.

The establishment of a national German REACH-CLP-Helpdesk was a well accepted support for the involved companies and played an important role in the communication between the concerned parties in order to implement the new elements of the regulations.

Keywords:
REACH; Chemicals Regulation; SVHC; Authorisation; Candidate List; Restriction