Position paper - A private sector view on REACH and competitiveness - 2017 REFIT evaluation key to addressing outstanding obstacles

Members of the American Chamber of Commerce to the European Union (AmCham EU) are active stakeholders in the Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation (REACH) and have experienced its procedures first-hand.

Over the past few years, the implementation of REACH has improved and to some extent become more predictable. The adoption of the Risk Management Option Analysis (RMOA) and of the Substances of Very High Concern Roadmap are the most visible signs of such improvements. Nonetheless, AmCham EU believes more could be done to guarantee REACH delivers on safety without jeopardising competitiveness and innovation in Europe. The 2017 REACH evaluation is the perfect opportunity to do so.

The impact of REACH on competitiveness is about much more than compliance costs. AmCham EU wants to illustrate in what ways REACH impacts competitiveness early on in the REACH evaluation process, to help frame the discussions going forward.