||REACH UPDATE (May 2009) - Seven Priorities for Optimising Implementation of REACH: Lesson learned from the first two years
Jun 10, 2009
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Executive summary Two years after its entry into force, BUSINESSEUROPE has carried out a first assessment of the implementation of REACH with a view to drawing the attention of European and national authorities to European industry's experiences, successes and difficulties encountered so far.
BUSINESSEUROPE has identified seven priority areas for action:
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- The financial burden on companies should be reduced. Phased payment of registration fees first and lowering of fees in the longer term is required.
- Consistent European chemicals legislation needs to be guaranteed. Chemicals rules must be set using uniform criteria and consistently in one place. REACH must be in this place.
- The quality of guidance about industry's REACH obligations should be improved to avoid legal uncertainty. A strong and timely representation of industry in Partners Experts Groups and translation of Technical Guidance Documents into all EU languages will help improve the situation.
- Truly harmonized REACH rules across Member States should be ensured, especially in terms of enforcement activities. Attention should be given to industry’s practical experiences.
- The efforts of the European Chemicals Agency (ECHA) and the Commission to involve industry are much appreciated. The REACH Helpdesk Correspondents' Network should involve industry better.
- Impacts of REACH on international trade should be looked at very carefully. Clarity about non-European companies' obligations and full compliance with WTO rules must be ensured with a view to a real level playing field.
- ECHA's online platform to submit data and dossiers on chemical substances (REACH-IT) must be fully operational. Making the system available in all EU languages is worth close consideration, especially for facilitating SMEs' work.