Effect of some legal interventions under REACH and CLP

The REACH authorization process is costly and labor intensive for industry (applicants) and authorities. In order to get light on the effectiveness of this effort, the current project analyzes trends in SPIN volume data to see if conclusions can be drawn as to the relative importance of various legal interventions.

Previous studies have investigated and assessed the extent to which the REACH authorization process for Substances of Very High Concern (SVHC) drives substitution of these substances. Based largely on stakeholder interviews, it is qualitatively assessed that inclusion of substances in the Candidate List and possible later inclusion in the Authorization List (REACH Annex XIV) contribute to driving substitution and reducing exposure along with other legislation and other market factors.

The current study focuses on volumes in the Product Registers in Denmark, Norway and Sweden as available in the SPIN database, with non-confidential registration information from the four Nordic registers.

The study focuses on the 43 entries in the current Authorization List by plotting the developments in amounts in the four Nordic countries over the years against three regulatory dates; trigger date, date listing and authorization list inclusion date.

The current study clearly states that regulatory action (including harmonized classification / assigning the SVHC designation) over the past decades on substances currently on the REACH Authorization List has resulted in considerably reduced tonnages in the Nordic countries.

It appears that candidate listing and authorizations list inclusion generally keep or drive ton-nags to low levels and thus may function as drivers for eventual substitution in situations where it would be difficult to identify substitutes in the short term.

The findings of the project cannot support that one type of legal intervention (eg harmonized classification) is more than less important than another (eg candidate listing or Annex XIV inclusion). 

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