Environmental Project no. 2087, 2019

Effect of some legal interventions under REACH and CLP

Exemplified with notification volumes in the Nordic Product Registers

The REACH authorisation process is costly and labour intensive for industry (applicants) and authorities. In order to shed light on the effectiveness of this effort, the current project analyses
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 authorisation 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 Authorisation 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 notified in the Product Registers in Denmark, Norway, Sweden and Finland 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 Authorisation List by plotting the developments in notified amounts in the four Nordic countries over the years against three regulatory dates; trigger date, candidate-listing date and Authorisation List inclusion date. The current study clearly indicates that regulatory action (including harmonised classification/assigning the SVHC designation) over the past decades on substances currently on the REACH Authorisation List has resulted in considerably reduced tonnages in the Nordic countries. It appears that candidate listing and Authorisation List inclusion generally keep or drive ton-nages 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 (e.g. harmonized classification) is more or less important than another (e.g. candidate listing or Annex XIV inclusion).


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