BSEF Position Paper Essential Use of Flame Retardants

REACH Restriction and Authorisation are the two main regulatory processes for addressing the “most harmful chemicals”. As the Essential Use concept is proposed to be linked to the management of such chemicals, inclusion of the Essential Use Concept needs to complement the existing Restriction and Authorisation. As such, we believe the Essential Use Concept should be limited to SVHC substances.

REACH covers (almost) all chemicals. Therefore, the criteria for essential use need to be flexible enough to take into account the wide range of important uses of chemicals under REACH. There are chemicals with hazardous properties that are used safely and that have a very high benefit for society. However, according to the definition of essential uses in the Montreal Protocol these uses would not be considered as essential.