REACH Restriction: Implications for companies

The aim of REACH restrictions is to protect human health and the environment by limiting or banning the use, manufacturing, or marketing of chemicals that pose unacceptable risks. Restrictions are applied when it’s necessary to control hazards that cannot be adequately managed through other regulatory measures, ensuring consistent protection across the EU.  

EU member states or the European Chemicals Agency (ECHA) can propose restrictions if they find that certain chemical risks are not adequately controlled and should be managed across the EU. Restrictions can limit or ban the manufacturing, marketing, or use of a substance. These restrictions may apply to any substance on its own, in mixtures, or in products, including those that don’t require registration. ECHA can also propose restrictions on products that contain substances listed for authorization.  

The REACH Restrictions Roadmap is a strategic plan developed by ECHA and the European Commission to address harmful chemicals more efficiently across the EU. Its main goals are to prioritize, evaluate, and restrict groups of hazardous substances that pose risks to health or the environment. This roadmap is now under implementation.  

Restriction scope: Restrictions are tailored to address the risk identified meaning that the scope will be tailored to address the risk while ensuring prop socio-economic impact, availability of alternatives, proportionality and enforceability.  Derogations from the restriction such as longer transition periods before the restriction comes into force can be requested in the process. Any request needs to be supported by robust evidence.  

Restriction impact: A restriction on a chemical or group of chemicals can impact value chains in particular if alternatives are not available and/or approvals are needed under product legislation to implement changes. For example, the universal PFAS restriction proposal aims to ban the use and placing on the market of 1000’s of PFAS chemicals that have very wide uses across most sectors (manufacturing, storage, transport, defence, mining, energy, etc.). The impact of the ban may be felt far down the value chain when a key chemical can no longer be used.  

Restriction process: There is a formal process for proposing, assessing and adopting REACH restrictions. Stakeholders can provide input in the calls for evidence and the public consultations organized by ECHA during the process.  

Do you need support responding to calls for evidence and the public consultations? We offer services for every step in the process! 

Learn more about REACHLaw Restriction Services through the following link: https://www.reachlaw.fi/reach-restriction-services/  

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