REACh restriction procedure: how can you contribute before the regulatory text is adopted?

Source ANSES

Member States, or ECHA at the request of the European Commission, can propose a restriction at any time. This proposal will then be evaluated at European level, with the result that an opinion may be issued either :

• fully support the proposed restriction ;

• support the proposed restriction, but on condition that some changes are made;

• reject the proposed restriction.

The European Commission will then decide on the legal text of the new entry, which will appear in Annex XVII of the REACh regulation.

Providing information before or at the restriction proposal stage can help you better anticipate the changes needed in your company. Particularly if you need to adapt conditions of use, or set up a substitution plan.

What's more, this proactive approach allows you to contribute to the process before the regulatory text is adopted.

Whether you are a manufacturer, an industrial user or a professional user, you use substances subject to the REACh regulation and likely to be subject to restrictions [FIC 0157] , i.e. listed in Annex XVII of the regulation.

If you are concerned by a restriction [FIC 0157] , but consider that it is not adapted to the specificities of your company, you can contribute during the procedure (which lasts 15 to 18 months [FIC 0157] ) before the adoption of the legal text.