Position paper - Streamlining and simplifying the REACH authorisation for applications concerning uses of substances in low volume and legacy parts

The REACH authorisation process was designed to deal with large volumes of chemicals with the assumption that alternatives could be found in a relatively short period of time. It is a lengthy, bureaucratic and expensive process. “Upstream” may be proportionate and “fit for purpose”, but at or near the end of the “downstream” and for “legacy parts” it is a disproportionate burden. So disproportionate in fact that it is endangering the competitiveness of manufacturing in the EU and risks forcing the premature obsolescence of products. One size definitely does not fit all, and we fully support the objective of building a simpler, proportionate procedure.
AmCham EU believes that authorisation procedures can be simplified so that they focus on pragmatic chemical risk management - not on trying to impose an unwieldy and unsuitable administrative burden on downstream users. In this paper we have outlined the type of products and processes that should qualify for simplified authorisation, together with possible simplified solutions.