| Tiivistelmä | This is the final report of a project studying whether amendments should be made to Annexes II and III (setting out exemptions to the Registration requirements) of the European Commission’s proposal for a new EU chemicals strategy (known as REACH - Registration, Evaluation and Authorisation of Chemicals). This report is drawn up by Andrew Fasey (Protection Through Knowledge Limited) and Seppo Koskinen (Inherent Engineering Oy). The study was commissioned by the Ministry of Trade and Industry, Finland and the Ministry of Social Affairs and Health, Finland.
The study took as its starting point how certain substances identified by Finnish companies and sector organisations are treated under the Registration requirements of REACH.
In particular, the substances identified were those where the respondents believed that their treatment under REACH was disproportionate, open to interpretation or should otherwise be treated differently. The responses led to a number of key issues being identified that were relevant to Annexes II and III. Options for addressing the issues were
identified and a number of recommendations have been made.
Annexes II and III were considered by many respondents to be confusing and inconsistent. This causes problems with the workability of REACH and may also have negative
consequences for human health and the environment and/or may have economic consequences either for individual companies or for the EU as a whole. The report’s conclusion is that amendments are needed to Annexes II and III, associated Articles, the Recitals, and in supporting guidance to improve the consistency, coherence,
proportionality and workability of REACH. These amendments need to be made in such a way that the objectives of REACH continue to be met. This would enhance the implementation
of REACH in several industrial sectors, in particular basic metals, paper and food industries, and clarify the practices concerning a variety of naturally based industrial
raw materials. |