Five years REACH: lessons learned and first experiences - an industry’s view

Abstract

Five years after the entry into force of the European chemical regulation REACH, the chemical industry has done much build-up work under difficult framework conditions, in order to implement REACH. Now it is decisive to benefit from lessons learned, simplify procedures and agree on solutions for existing problems - in a fair and transparent communication process between the stakeholders concerned and the competent authorities.Results and conclusionsThe REACH Regulation is highly complex, and its requirements need to be implemented step by step. Practical implementation is a learning process for everyone involved: companies and competent authorities alike. Up until now, implementation is working generally. Only first experiences are just being gathered on many aspects so that it is much too early for a valid evaluation.Cost and workload for registrations are immense for the chemical industry. Therefore, now, the experiences from the first registration phases need to be used for simplifying the procedures and making them more efficient.In the evaluation, the expectations of the competent authorities and of the companies need to be aligned with each other. Scientific issues are to be resolved. Here, it must be ensured that well-founded expert opinions find acceptance and that alternative assessment methods find their place. A fair and transparent communication between the competent authorities and the companies on existing points of criticism is a basic prerequisite for improvements.Studies show that the new extended safety data sheets under REACH are seen as overly comprehensive and unintelligible, both by those compiling them and by users. Therefore, forthcoming activities need to aim at simplifying the procedure and making it manageable also for smaller enterprises.The authorisation procedure is increasingly being politically exploited. This should be adjusted in support of focussing on real risks and analysis of management options which should be open in its results and involve the industry in an early stage.The chemical industry is working at high pressure on complying with its complex REACH obligations. It needs a stable environment, i.e. workable requirements and reliable planning. Fundamental changes to the Regulation would put at stake what has already been achieved.