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REACH Authorisation
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Prioritisation of Substances of Very High Concern

Briefing for Industry Action

► Endurance

It is a tough undertaking to maintain vision and focus in a complex group of industrial stakeholders indefinitely . Companies may adopt alternative strategies regarding the use of the SVHC and interests may become difficult to reconcile. Yet it is important to keep a forum open to ensure that the necessary updates of the Registration dossier occur and are financed and that good data on uses and tonnages are available to the authors of the prioritisation proposal and other Member State authorities.

Depending on when the prioritisation is considered as some time may have passed since the identification as an SVHC, Member State experts may want to revisit or update the RMOA. As a resource, Industry should be prepared to provide either ‘extensive’ or ‘synthesized’ data that can be processed efficiently.

Do preserve the value chain dynamics.
Do remain the preferred source of information on the industry and alternatives.

At this stage of the process, there are no inextricable competition issues that would prevent the consortia from being the major source of information. They should in any case play a key role in the updating of the Registration dossier! Consortia or trade associations can also coordinate the final consultation process.

Do always provide information that is backed by solid underlying data.

Confusion in the minds of ECHA and Member State experts should be avoided at all cost. Therefore, the following hierarchy of information provision may be considered:

Consortia or trade association: all information that could be considered generic or that can be shared collectively such as:

  • Update Registration dossier, including review of the exposure scenarios that may be unfit for Authorisation purposes, e.g. variety of exposure situations in ‘surface treatment’.
  • Provide an overview of existing regulatory provisions
  • Provide generic value-chain descriptions, including socio-economic information (employment, exposure to non-EU competition etc.)
  • Provide reality-check information on exposures and risk management measures
  • Collate – maybe peer-reviewed – generic up-to-date information on alternatives

Companies:

  • Relevant specific information
  • When their use is unique, hence mostly not covered by a consortium, information that is relevant and backed up by data on use, exposures, markets and alternatives
  • Indications on whether and why their use may be exempted from Authorisation
Do consider who is the best actor in the supply chain to apply for an Authorisation. Is it better to prepare and submit an application separately or jointly?

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