REACH: a new version in 2022?

Revision of the Reg. EC n. 1907/2006 is expected

Along the last 2-3 years, an intense debate has occurred over the systematic revision of the REACH regulation (EC Reg. n. 1907/2006) to adapt it to the scientific progress concerning some specific scientific/regulatory assessments and, on the other hand, to modernize it based on the huge experience due to its multiannual application (since 2007). Two main actors are involved in such a debate: the EU Competent Authorities, mainly EU Commission, ECHA and Members states on one side and the industry representatives on the other side. Their legitimate visions and experiences acquired during the 14-year application need to reach a shared synthesis in the new expected Regulation. Other stakeholders involved in such revision are indeed the Scientific Community (which needed support for topics as Endocrine Disrupting Chemical and combined Risk Assessment of substances and mixtures) and the Civil Society (all of us), who are the ones who benefit from the practical application of the Regulation. Moreover, the REACH revision will also be the result of the recently announced EU strategies concerning the European Green Deal towards a toxic-free environment and the Circular Economic strategy to reduce chemical production, avoiding SVHC (Substances of Very High Concern) chemicals in recycled materials. Many other topics will affect such REACH revision, even not directly concerning chemical safety.
Among these, we can mention:
§  Batteries Directive mainly in relation to the expected development of e-cars and electronic devices in general
§  The EU strategic approach to pharmaceutical into the Environment (PIE)
§  Occupational Safety and Hygiene (OSH) legislation
§  Waste legislation in connection with the Circular Economy strategy and the problem of SVHC in articles
§  EU ecolabel
§  Drinking water§  Fertilizers§  Connection with the 7th Environmental action plan.

The year 2022 (15 years after the first application) is awaited for the new regulation release. The two actors have different views on the content and principles of this new document. EU Commission seems to be oriented to a partial revision of the Regulation with an extension of the application of SVHC, polymers and mixtures, and a simplification of some processes like restriction and authorization; the industry is not favouring a complete revision but only for some focused topics. Industry evokes a more balanced strategy and not a complete revision of the REACH regulation that can increase chemical companies’ burden again. A balanced strategy means a document that can integrate the hazardous properties of the chemical substances that need to be well known and manage. With their risk assessment and considering the huge benefits, chemical substances can drive a safe environment and a good Circular Economic application. The industry does not agree with the use of statements like “toxic-free” and “non-toxic”, preferring “safe” and sustainable”. Theoretical versus practical approach? A dialogue is hence necessary before the release of the new document! The main regulatory matters that are expected to be implemented in the REACH Revision 2022 are the following:

§  Combined exposure.
§  Polymers and polymers of concern.
§  EDS Endocrine Disrupting Substances.
§  Chemical substance and environment.
§  Waste, SVHC and recovered substances.
§  Dossier quality and update.

 The expectations for REACH regulation review in 2022 is very high. Most of the listed topics have been discussed for years. Some others are moderately new but need attention as well. All together they lead to extensive revision work and a final 2022 document that needs to be a pragmatical synthesis of scientific criteria and regulatory approaches.

Dialogue with main stakeholders is essential. The 2022 REACH regulation may have crucial consequences and impact various sectors, including society.

All stakeholders are invited to contribute to a successful final release in the future European strategies for Green Deal, Circular Economic, and a future safer environment.