On 31 May, the CRM Alliance submitted feedback to the the European Commission's open consultation on the roadmap for the revision of the REACH Regulation.
The European Commission published the Chemicals Strategy for Sustainability (CSS) as part of the EU’s zero pollution ambition, which is a key commitment for the European Green Deal. The CSS aims to ban substances of concern in order to protect human health and the environment. In the frame of the CSS, the Commission proposed the revisions of the REACH regulation and the hazard classification, labelling and packaging of chemicals (CLP) regulation.
Members of the CRM-A are directly impacted by the REACH Regulation and have first-hand experience with the challenges that this legislation brings. The CRM-A supports the promotion and protection of the use of CRMs through the revision of REACH, given their life improving properties and their non-substitutable use in existing and future applications.
In particular, the CRM-A (1) supports resolving regulatory inconsistencies between REACH/CLP and/or EHS/OSH, (2) encourages a scientific based assessment of substances which takes into account the scientific findings of the industry when determining the essential use of a substance under REACH and (3) prefers a risk-based approach in REACH substance evaluations over a hazard-based approach.
To read our submission, please click here.