Recently, the European Commission released a research report on the overlap of REACH regulations to assess whether the REACH regulations overlap with other EU-related regulations and need to be revised. The report has a total of 428 pages and contains 38 practical recommendations for action. The details are summarized below:
"Double Law"
Some regulations contain restrictions on specific substances or specific uses that are similar or contradictory to the restriction requirements in Annex 17 of the REACH regulation, such as the Polychlorinated Biphenyls and Polychlorinated Terphenyls (PCBs/PCTs Directive), the Toys Directive and This is the case with packaging directives.
In response to this situation, the report recommends that relevant regulations be modified to avoid duplication or inconsistency. The report also recommends the establishment of a database for restrictions on specific substances to provide query.
"REACH exemption substances lead to lack of risk assessment"
The report noted that substances exempted from the REACH regulations include medical products, cosmetics and plant protection agents or pesticide products. The exemption of substances leads to a lack of risk assessment. The reason for this is that safety assessments originating from the product manufacturing, mixing and disposal stages are not regulated by specific departments. The report provides different revision suggestions for each industry regulation's risk assessment gaps.
「Multiple regulations increase response costs"
In most cases, the information required by REACH regulations cannot meet the requirements of relevant industry regulations, resulting in companies being unable to accurately save costs. The report recommends the development of guidelines to address this issue.
"Complementarity between CLP regulations and REACH regulations"
The study also found that Article 37 of Chapter 5 of the EU Chemical Classification, Labeling and Packaging Regulation (CLP) regarding the process of unified classification is inconsistent with
The content of Article 59 of the REACH Regulation is similar, so the report suggests that a broader mechanism can be used to include those substances that comply with the CLP Regulation and are also included in the candidate list of the regulatory scope of Article 57 of the REACH Regulation, so that
There is no need to carry out substance identification according to Article 59 of the REACH Regulation. Likewise, similar measures are recommended for substances in Annex 6 of the CLP Regulation.
The report assessed a total of 155 EU regulations in addition to the EU REACH regulation; the research content will be included in the REACH regulation review program, which is conducted by the European Commission in accordance with the requirements of Article 138(6) of the REACH regulation, in order to avoid conflicts with other regulations. The relevant EU regulations overlap, and the European Commission should conduct a review within the specified time to evaluate whether to amend the REACH regulations.
Source: Chemical Watch (PIDC compilation 2012-05-04)
http://chemicalwatch.com/10989/european-commission-publishes-reach-scope-review
Research report on the overlap of REACH regulations
http://ec.europa.eu/enterprise/sectors/chemicals/files/reach/review2012/scope-final-report_en.pdf
