ChemSec letter to Bjorn Hansen (ECHA)

Your substances


Note: This is the third letter in an on-going discussion between ChemSec’s Executive Director Anne-Sofie Andersson and her counterpart at Echa, Björn Hansen. You can read the first letter from Ms Andersson here and Mr Hansen’s response here.


Dear Mr Hansen,

Thank you for your thorough answer to our concerns and to the specific questions we put forward. I am glad to hear that you enjoy your new position and I appreciate your dedication to make ECHA work more effective.

As an agency, I understand that you need to follow agreed procedures, such as the SVHC roadmap, and looking at this specifically I understand your view that the roadmap is doing well.

Coming from the outside, and therefore possibly with a zoomed-out perspective, I stand firm in my opinion that the pace of populating the Candidate List has been far too slow. I cannot see that this will improve within the current roadmap.

I am glad to read from your answers that we agree on the following: i) Non-registered substances can also be relevant for the Candidate List, ii) CMRs are not necessarily adequately controlled through requirements following on classification, iii) It can be advantageous to have restricted substances also on the Candidate List.



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