Analysis by ChemSec and ClientEarth shows the chemicals approval process gives undue influence to companies producing dangerous chemicals and stifles information on safer alternatives, limiting the market for companies that produce them.
The main goal of the authorisation process is to promote the replacement of substances of very high concern (SVHC) with substances or technologies that are safer.
However, during the “stocktaking conference on authorisation” held in November 2017, it emerged that the authorisation process has not delivered its full potential. In particular, authorisations have been granted even when alternatives did exist, contrary to the requirements of REACH and having negative effects on alternative providers.
On the basis of the conference on authorisation, experience as observers in the socio-economic committee (SEAC) and extended exchanges with alternative providers, ChemSec and ClientEarth have identified two of the issues in the way SEAC operates, that prevent the authorisation process to fully deliver.
First, applicants do not always comply with their obligation to provide ECHA with accurate and comprehensive information on alternatives. The way to find existing alternatives has to be re-thought.
Second, SEAC does not use clear and appropriate criteria to assess the feasibility of suitable alternatives. The way that SEAC assesses the feasibility of alternatives needs to be improved.
This publication aims to explain the current challenges and recommend solutions that could be implemented without changing the existing regulatory framework.