REACH enforcement: Quality Observation Letter (QOL) and Statement of Non Compliance (SONC)


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At the Chemical Watch Regulatory Summit, held in Brussels on the 14th of October 2014, as part of a day of presentations and discussion about enforcement of EU chemical laws like REACH, Michael Warhurst, Executive Director at CHEM Trust, emphasised that REACH does not provide a high level of protection for human health and the environment if companies can dodge their legal responsibilities or if they can register chemicals with poor quality or incomplete information.

Two important issues were highlighted:
  • Quality Observation Letter [QOL]. The REACH Regulation proposes that at least 5% of registrations are checked (‘evaluated’), and that companies that haven’t done a good job will begin a process which could lead to enforcement action. However, ECHA created a new checking process called the ‘QOL’ in which companies, in case of poor quality registrations, were just asked to provide new information. This immediately removed the incentive to do a good submission, as a bad submission could be improved when the chemical was evaluated.
  • Statement of Non Complinace [SONC]. If a registration is evaluated and found to be deficient, then a ‘SONC’ will be sent to the company and to the government of the EU country it is registered in. It is up to this government to take any enforcement action against the company. The EU has limited powers to enforce any legislation outside competition law. But there is massive variability in how much enforcement different EU countries actually do. NGOs like CHEM Trust would like to make public the name of companies to which SONCs had been sent to create public pressure but the name of the company is kept confidential by ECHA.


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