Prioritisation of Substances of Very High Concern
Briefing for Industry Action
Industry needs to be able to very quickly provide pertinent answers to any information requests from a Member State or ECHA or to prepare its contribution to the Public Consultation when it is launched. Prioritisation may happen very quickly and time might be too short to start collecting data at that stage. All the more reason to get organised at the SVHC identification stage!
There might be little time to come up with a solid argumentation in favour of postponing the ‘latest Application date’, for example. All options regarding the time needed to apply for an Authorisation should ideally already have been identified or anticipated in a ‘shadow RMOA’. Input will be needed from all interested parties including those not directly involved in the Authorisation procedure, i.e. end-users of articles who nevertheless may have the key information on the ultimate and decisive functionality provided by the SVHC.
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