REACH aus der Sicht des Umwelt- und Verbraucherschutzes

Abstract

REACH has been initiated with the aim of improving existing legislation. In order to assist in the interpretation of the REACH legislation, guidance documents have been developed, which have only lately become available. According to the REACH annexes and supported by guidance documents, waiving of test requirements will be possible, thus, opening the possibility that under REACH no new (eco)toxicological data will be required. Concerning products, a guidance document was released in April 2008 stating that the substance concentration threshold of 0.1 % (w/w) applies to the article as produced or imported and it does not relate to the homogeneous materials or parts of an article, but relates to the article as such (i.e., as produced or imported). Hence, notification will not be required for many products containing chemicals with properties which place them on the candidate list for authorization. In summary, it is at present not foreseeable whether the expected benefit of the REACH legislation will materialise for the environment and for the health of consumers and at the work place.