PANEL 5: Substances of concern (SVHCs) in products – whose job is it to control these in a free trade world? - Remi Lefevre, Scientific Officer, ECHA

1. Panel 5 – Substances of
concern in products – whose
job is to control these in a free
trade world?
09 June 2017
Helsinki Chemicals Forum 2017
Rémi LEFÈVRE

2. 2
Manufacturer
Formulator
End user /
Article producer
Import of
articles
Article
assemblers
Article retailers End users of articles
Comprehensive set of
obligations for
information generation
and communication
within supply chains
- Less information
- Less substances: Candidate
List substances only!!!
What does REACH foresee?

3. 3
What we observe…
EU-made articles
In REACH Registration dossiers:
• description of use in articles
is lacking or too generic
• exposure assessment
methods/tools lacking
• no waste stage information
Imported articles
• very limited information /
no updating
• 368 notifications, for 39
Candidate List substances
• limited enforcement
Poor compliance!

4. 4
The consequences (1/2)
For retailers (EU importers):
• responsibility left to their suppliers on
the safety of the products they sell (risk
of crisis)
• limited ownership of their products
For users of articles/consumers:
• no information on what is present in
articles  no “right to choose”
• limited or no information on how to use
(and dispose of) products safely

5. 5
The consequences (2/2)
For regulators:
• difficult to identify potential sources of
concern
• and to regulate quickly and efficiently

6. 6
Why?
Are supply chains:
 too complex?
 with too different actors?
 too volatile?
Are materials’
compositions
changing too
quick?
Other reasons?
?

7. 7
What shall be done?
Awareness
raising
Regulatory measures
& enforcement
By whom?
Guidance /
Support to development
of standard
communication formats
or IT tools

8. 8
Effective
supply chain
communication
Manufacturer
Formulator
End user /
Article producer
Article
assemblers
Article retailers End users of
articles
Manufacturers
Article retailers
End users
of articles
The right model?
REACH

9. Thank you!
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