What EU Commission doesn’t want to achieve with Authorisation
We are taking part in the second day of ECHA’s event about Authorisation and here some updates to keep you in the loop:
What the European Commission does not want to achieve with authorisation:
• Only companies with deep pockets applying
• Smaller player being kicked out
• Substitute EU production by imported products
• Burdensome and costly and bureaucratic procedure
• Postpone substitution longer than necessary
• Discourage substitution/discourage business producing/using safer alternatives
• Substitute with potential SVHCs
• Discourage innovation
So where is the problem?
• Applying for authorisation is costly and burdensome, why?
• Broad scope (no volume threshold, all uses, wide range of operators covered)
• New, relatively broad and demanding obligations
• Some elements are not regulated in detail (SEA, AoA), external expertise may be needed
• Supply chain coordination is a must
• Not much experience or reference cases
What is EC doing?
• Legal interpretation and guidance
• Streamlining and simplification of authorisation application procedure in specific cases
• General streamlining of authorisation applications (all cases, more fit-for-purpose)?