The committee considered merging reach regulatory restrictions and authorization procedures

In order to achieve the goal of zero pollution in a non-toxic environment proposed in the European Green agreement, the European Commission issued an important road map on May 4, 2021, proposing to amend the REACH Regulation (hereinafter referred to as the reach regulation amendment initiative), and solicited opinions publicly. The deadline is June 1, 2021. It is planned to issue the reach regulation amendment proposal by the end of 2022.

The reach regulation revision initiative aims to address all issues from registration and evaluation to authorization and restriction of chemicals in order to improve the existing REACH regulations. We focus on the following issues:

Low communication efficiency in the supply chain. The communication between upstream and downstream of the supply chain about the use and necessary risk management measures lacks accuracy and clarity, which has a significant negative impact on risk control.

The authorization process is cumbersome and inflexible. The authorization process has brought a heavy burden to both the company and the authorities. A large number of authorization applications for only a small amount of substances, unclear authorization standards and information gaps, and unclear information in the application all lead to a long time of discussion and decision-making delay. In addition, authorization requirements also put EU companies at a competitive disadvantage compared with non EU competitors.

The current restriction process is too slow to protect consumers and professional users from harmful substances. The normal limiting procedures based on specific risk assessment make the authorities tired of recording the unacceptable risks of hazardous substances to human health or the environment. There are still some deficiencies in the existing restriction procedures to include endocrine disruptors, PBT / vpvb and other substances into the restriction. In addition, professional users cannot get effective protection.

Options for REACH regulation revision initiative:

■ simplify communication in the supply chain: the European Commission will assess options for improving the safety data sheet, which provides downstream companies and workers with information on chemical risks and protective measures, particularly in a unified electronic format.

■ reform of authorization procedures: the options include: clarifying and simplifying the current provisions, authorizing the authorized substances for small batch use by Member States, deleting authorization requirements from reach, integrating authorization and restriction procedures according to the principle of "one substance, one assessment", and improving the connection with other regulations.

■ reform the restriction procedure: the alternatives include: extending the general risk approach to the restriction of endocrine disruptors, PBT / vpvb substances, immunotoxic substances, neurotoxic substances, respiratory sensitizers and substances affecting specific organs; Extending the general risk approach to products sold for professional purposes; The concept of essential use in universal restrictions, including the criteria for obtaining exemption.

GIG reminder

The reach regulation revision initiative will greatly revise the current reach regulations. Export enterprises should always pay attention to the changes of regulations, plan the response methods in advance, and avoid risks.