The non-Governmental Organisations (NGOs) Client Earth and the European Environmental Bureau (EEB) have published a report entitled “Identifying the bottlenecks in RE ACH implementation: The role of ECHA in REACH ’s failing implementation”. This report is a critique of the implementation of REACH since the legislation was adopted, and tries to be balanced in identifying the successes and failures of ECHA (the European Chemicals Agency) and reasons for these.
One specific issue raised in the report concerns unambiguous identification of chemical substances. Article 11 of Reach states that a fundamental principle of REACH is that for each substance there should be only one registration – but the report makes clear that this is not always the case, and that ECHA have reported that 72% of the shortcomings in dossier evaluations were related to substance identity. This highlights the extremely important role of good quality chemical measurements, to identify and quantify both components and major substances, and the need for applicant chemical producers to properly characterise substances.
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