The on-going open public consultation on the REACH Revision closes on 15 April, 2022

The on-going open public consultation on the REACH Revision initiated by the European Commission on January 20, 2022 will run until April 15, 2022. All interested stakeholders such as the chemical industry, industrial associations, SMEs, businesses and citizens have until next week to submit their views on the targeted revision of the REACH Regulation. It aims to support the EU’s ambitions on sustainability, innovation and a high level of protection of human health and the environment from chemical substances, as specified in the Chemicals Strategy for Sustainability (CSS) published on October 14, 2020.

The REACH Revision is likely to increase regulatory obligations and business impacts for chemical manufacturers and formulators, importers, downstream users (DUs) and producers of articles and complex objects in the EU/EEA. Consequently, it is important that these actors will participate in the on-going consultation to ensure that their interests are taken into account.  

Let’s take a look at the possible key elements of the targeted REACH Revision:

  • Revision of Registration requirements, incl. additional information requirements: critical hazard properties, endocrine disruptors, environmental footprint, use and exposure (incl. possible new DU reporting to ECHA for hazardous substances), CSRs for 1-10 t/y, registration of certain polymers of concern, DMELs, Mixtures Assessment Factor(s) (“MAF”)
  • Revision of Evaluation requirements, incl. registration “expiry date” and revocation of registration numbers (persistent non-compliance / no action), possible enhanced ECHA checks at submission stage, etc.
  • Simplified Supply Chain Communication (electronic SDS format) 
  • Reform of Authorisation and Restriction
    • Candidate List: Additional SVHC categories and enhanced role as priority tool
    • Possible new reporting obligations for Downstream Users of identified SVHCs
    • New hazard classes (“most harmful chemicals”) and extension to professional use for fast-track restrictions (“GRA*”)
      • *GRA = Generic Approach to Risk Management
    • Essential Use Concept (EUC) – including to streamline the process of granting authorisation/deroations from restriction and speed up the phase-out of non-essential uses of the most harmful chemicals.
  • Revision of provisions for Control and Enforcement (one focus on imports) and European Audit Capacity
  • Other changes, e.g. clarification of “intermediate” definition

REACHLaw is following the developments of the REACH Revision closely, working closely with our clients to inject critical input into the various on-going consultation activities, and will continue sharing key information on the implications of this targeted “revision” for the chemical industry and other industry stakeholders.

You can contact us at any time at if you wish to discuss on how the REACH Revision may affect your business, and how to contribute effectively to consultations.

More information on the REACH Revision can be found on our YouTube channel REACHLaw Talks: HERE.

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