In a letter to the institutions the EEA EFTA states point to specific aspects of improvement as the attempt to increase the level of protection for health and the environment, and simultaneously, improve the efficiency of the proposal.
The EEA EFTA states stress the introduction of the principle ‘duty of care’ into the REACH regulation – stating the legal principle as essential in portraying a “message to producers and importers to take the responsibility of their products”. Norwegian legislation on chemical products has utilized the ‘duty of care’ principle for many years and achieved positive results.
As regards to the new European Chemicals Agency the EEA EFTA states emphasize the importance of their direct involvement as a natural extension of the EEA agreement.
The letter also points to chemical substances that pose a high risk to health and the environment as REACH priorities, further proposing a stronger emphasis on deadlines and set targets to achieve compliance – which is absent in the Commission proposal.
The EEA EFTA states acknowledge REACH as a positive initiative towards the identification of chemical risks, as well as its potential as an important means of protecting the environment and the health of European citizens.
In connection to risk assessments in the work environment, Norway, Iceland, and Liechtenstein further stress the importance for suppliers to submit Chemical Safety Reports (CSR).
The comments by the EEA EFTA states is sent in connection to a study conducted by CEFIC and UNICE, under a Commission mandate, which examined the impact of the chemical substance proposal on relevant actors. Industry concerns about potential negative effects of REACH onto the supply chain initiated the study, the results of which were released on 27 April, and that further will be assessed by a High Level Group.
Relevant industrial actors and businesses, and NGOs have contributed to the development of REACH, as its establishment is a result of various studies and the accumulation of comments gathered after the Commission published its proposal on the Internet in 2003 for the purpose of receiving industrial feedback.
REACH proposes chemicals measuring one tonne to be registered in a central database administered by the new European Chemicals Agency that would provide non-disclosed information to the public. The threshold of one tonne is valid for one year per manufacturer.
Achieving a balance between the protection of health and the environment on one hand, and safeguarding industrial competitiveness on the other, has been a Commission priority for REACH – a parallel that has proven to be one of its main challenges.