Prioritisation of Substances of Very High Concern
In a Nutshell
► Industry’s role
This is the end of the process before a substance is put on the Authorisation List. It may be Industry’s last chance to prevent this happening. The pressure on ECHA and the Member States to deliver on Authorisation makes it very difficult to alter the course at that very late stage, especially during the last public consultation before the proposal is sent to the Commission.
The fact that it may be some time before the SVHC is considered for prioritisation forces Industry to remain vigilant and to very regularly update the critical data. Not being prioritised should not be considered a comfortable position. The SVHC stigma remains as well as the uncertainty: one never knows if a Member State is not ultimately going to propose prioritisation. At that stage, in addition to the participation in the consultations and the provision of updated data, some proactive steps may reduce the likelihood of prioritisation.
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