Position paper - How to improve REACH substance evaluation: AmCham EU’s recommendations ahead of the REACH REFIT evaluation

The American Chamber of Commerce to the European Union (AmCham EU) has been fully involved in recent discussions with the European Commission, the European Chemicals Agency (ECHA) and Member State Competent Authorities (MSCAs) on how to improve the process of applying for Authorisation REACH. We have shared our experience and sought to be a constructive actor in these debates in order to improve the process in the future. With this paper, we encourage authorities to consider a similar reflection on how to improve the process of REACH Substance Evaluation (SEV). Ultimately, it is through Evaluation that the largest number of chemicals are being assessed via REACH at the moment.

We acknowledge that genuine efforts to improve the SEV process have been made both by ECHA as well as some Member States and stakeholders. However, more can and must be done to enable further improvements. In particular, AmCham EU considers that a meaningful analysis and clarification of roles and responsibilities of all the actors is needed to improve the SEV process.

AmCham EU intends this paper to be a contribution to the 2017 REACH REFIT evaluation, which we would like to see address the current shortcomings we experience with SEV. This is all the more important since SEV is a decisive step before the selection of other regulatory measures.