REACH

The REACH Regulation is the EU’s main law on chemicals. It stands for the registration, evaluation, authorisation and restriction of chemicals.

It aims to ensure that chemicals and substances, including precious metals, are managed safely to protect human health and the environment.

Why is it important?

The REACH Regulation is at the core of the EPMF’s work. We have invested heavily in compliance and have registered over 100 substances under REACH. The REACH Regulation was last evaluated in 2018, and while it is generally effective, it could benefit from further improvements and simplification. The European Commission was expected to publish a revision of the REACH Regulation by the end of 2025 but the publication is postponed due to the negative opinion of the RSB, end of September. The EPMF continues to believe that it is critical to make the system more predictable, efficient and science-based.

  • EPMF KEY ASKS

As the REACH Revision is being prepared, the EPMF hopes that the updated proposal will prioritise risk management using clear data and exposure analysis. We call for improved predictability and transparency in REACH processes and we hope the revised Regulation recognises the unique properties of precious metals.
The EPMF supports the Commission’s efforts to simplify REACH to increase the efficiency and transparency in how chemicals risks are managed in Europe. More specifically, we call on the Commission to consider the following aspects for simplifying the REACH Regulation:

  • Ensure additional testing and information requirements for low-volume substances are related to their potential for exposure to workers, consumers or the environment.
  • Implement user-friendly systems with targeted questions to collect data and ensure data needed for the Risk Management Option Analysis is collected early in the process when a substance is considered for regulatory action. It is critical to avoid any delay in the Risk Management phase to ensure predictability for the companies.
  • Redesign the Authorisation system for very specific cases and adjust the prioritisation criteria to consider aspects like exposure.
  • Ensure targeted and implementable Restrictions based on unacceptable EU risk and covering the whole lifecycle.
  • Avoid automatic consequences in downstream legislation and communicate clearly when concerns have been addressed (e.g., by upgrading PACT).
  • Follow materials and their emissions through the entire lifecycle to ensure consistency and coherence with end-of-life, waste and recycling.
  • Avoid the integration of a default MAF in REACH for naturally occurring substances.
  • Consider the feasibility of enforcing the proposed REACH and non-REACH measures throughout all stages of decision-making

USEFUL RESOURCES:

For more information, check out our position paper on REACH.