Compliance Challenges of the Automotive Industry Concerning Obligations of Article 33 REACH

Abstract

In the last 15 years, the European Union has fundamentally renewed and expanded the regulation of chemicals. It inter alia integrated international treaties on substance use such as the Stockholm Convention on Persistent Organic Pollutants into the legal framework (in this case the EU-POP Regulation), regulated the use of biocidal products, and harmonised the classification, labelling and packaging of chemicals. As a central element, the REACH Regulation governs the complete supply chain for chemicals right through to the consumer with the aim of ensuring a high level of protection for human health and the environment. This examination compares the target state of the regulations from Art. 33 REACH with the status quo of the compliance measures in order to identify the delta in terms of compliance deficiencies. It also takes into account the incentives and impediments which influence the actors in the goal attainment. From these findings, the analysis concludes with recommendations for the relevant actors.