AmCham Position Paper | Reform of REACH Authorisation and Restriction

EXECUTIVE SUMMARY - As the European Commission considers the reform of the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) authorisation and restriction processes, it must pursue targeted, incremental improvements rather than a complete overhaul, such as removing the authorisation system and REACH Annex XIV. Instead, reforms should include, among other measures: streamlining the authorisation and restriction provisions; retaining authorisation as a potential risk management option where appropriate; better prioritising substances for further regulation; allowing industry to apply for derogations of general applicability; and using a harmonised and holistic set of criteria to assess derogations from regulatory risk-management measures. Above all, the principles of risk assessment and science-based decision-making must guide any revisions to REACH.