On May 3, 2024, Logika Group on behalf of DG GROW published a report summarizing conclusions from the first workshop on “strengthening the role of substitution planning in the context of REACH and other EU chemicals legislation”. The European Commission is studying how to strengthen substitution planning as part of the REACH regulation revision (FPF reported).
This first workshop used mixed stakeholder breakout groups to discuss different aspects of substitution planning. The group working to refine the exact problem definition raised the issue of “a lack of key data, including from registration dossiers, on exposure, [and] uses to enable efficient and effective regulatory decision-making.” Lack of access to proprietary information is regularly raised in discussions of chemical regulation and safety by civil society groups (FPF reported).
For the substitution plans themselves, “[p]articipants noted both individual and sector wide approaches may be appropriate.” A shared, sector-wide approach may be more efficient in many respects but it could lead to free riding, or for small and medium-sized companies it could be difficult to participate. Interaction could potentially focus on certain points in the value chain, or overall strategy developed at the sector level, but with implementation left to individual businesses.
There were similar discussions about who is responsible for the plans as they work through the regulatory process. “[I]t was agreed industry should lead the preparation of plans” but assessment of the plan could be done by either an established authority or a new entity put together for the purpose. Monitoring was equally hazy, with “no consensus on who undertakes it, nor how it should be done.”
The study will include one more workshop, likely in September 2024, and should be completed by the end of 2024. Videos from the workshop presentations and links to relevant documents are available from the European Commission.
References
Logika Group (May 21, 2024). “Study on strengthening the role of substitution planning in the context of REACH and other EU chemicals legislation. Workshop Report: Workshop 1.” DG GROW. (pdf)
European Commission (2024). “Substitution of targeted hazardous chemicals.”
Read more
European Commission (February 14, 2024). “Workshop for substitution of targeted hazardous chemicals supporting background document.” (pdf)
Logika (March 1, 2024). “Presentation: Study on strengthening the role of substitution in the context of REACH and other EU chemicals legislation.” (pdf)
