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REACH Restriction

The chemicals strategy for sustainability announced major regulatory initiatives including re-strictions encompassing a very broad scope of chemicals. The restriction of intentionally added mi-croplastics, and recently, the proposal for restricting PFAS are the latest examples of a new re-striction approach.

These far-reaching restrictions have a massive impact on a company’s portfolio, production process and access to the EEA market. Anticipation, thorough preparation and proactive engagement are key to secure optimum conditions for your business.

What are the new trends?

The broad restriction scope: the substances in scope of the restrictions are no longer identified by their name or CAS number, the substance scope is set by a complex definition. This makes it particularly difficult to identify substances in your portfolio and to survey your supply chain.

The burden of proof is reversed: while the competent authorities have to prove the unacceptable level of risk and propose derogations or transition periods to ensure proportionality, in practice this is very much based on the quantify and quality of the data provided by stakeholders during the calls for evidence. Proactive participation is key to increase your chances of obtaining derogations or long transition periods for the use of the relevant chemicals in your applications.

Analysis of alternatives is key: no matter how special your sector or application is, derogations or long transition periods will be only envisaged if you are able to demonstrate that you have made the effort to substitute but suitable alternatives are not yet available.

Socio-economic analysis of the impacts of the restriction on your business is of critical importance for the authorities, to inform them of the time needed by industry to comply with the restriction. The SEA must describe the most likely business response to a ban, in a credible way, supported by solid evidence.

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How we can help?

We have developed a full 360-degree service, from screening your portfolio to identifying the presence of substances subject to the REACH restriction, to proactive engagement with ECHA and the REACH-competent authorities during the consultation process.

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