LIFE 13 ENV/IT/00849

Report 2

Report 2 – Actual procedures and technologies supporting REACH Regulation implementation

One of the goal of Life+ inREACH project is to find solutions to problems related to the flow of information from manufacturers/producers/vendors located outside European Economic Area to importers and/or downstream users (and Consumers, though) within it. Import operations represent a very important share for sourcing of chemical substances or substances contained in mixtures and/or in articles specifically for SMEs and downstream users like formulators. ECHA (European Chemical Agency) is the driving force among regulatory authorities in implementing the EU’s groundbreaking chemicals legislation for the benefit of human health and the environment as well for innovation and competitiveness. It has a key role, though, in providing adequate IT support and deploying a common proper format for sending data about chemical substances and/or article manufactured or used as stated in the REACH and CLP Regulations and make this information available on its website. In order to support the different actors involved, ECHA made available a different set of ICT tools to fulfil the requested obligations. Moreover, heavy use of ICT targeting efficiency and the “going paperless” approach is also recommended by the Agency, since the fact that climate change mitigation is currently a high priority of European environmental policy. Available to the various type of actors, there are not only European level ICT tools, but even national ones, or legacy ones, as rules for information access actually combines publicly available information, mainly delivered via Internet, current systems of request for access to information and REACH-specific rules on the protection of confidential business. Project Beneficiaries carried out a complete assessment on the relevant REACH/CLP related ICT tools available. This huge amount of guidelines, tools, information, and more is not always easy to use, manage or understand, mainly due to the high number of pages, different features involved and amount of information. During the research activity that led to the deployment of Report 2: “Actual procedures and technologies supporting REACH Regulation implementation” and during the individual interviews also occurred at the National Launch Event of the Project, a lot of issues related to implementation of the REACH/CLP Regulations impacts over the Supply Chain emerged. In general terms, Critical Issues related to the topics discussed may be gathered under two main categories:

  • general practical difficulties in accessing and use of ICT Tools (e.g. IUCLID5);
  • issues emerging from overlaps and incoherence between systems available.

The Critical Issues related to this topic can be summarized as follows:

CRITICAL ISSUE

  1. Users facing difficulties in use of available ICT tools, especially from a usability point of view: e.g. consultation of ECHA web site, use of REACH-IT or IUCLID5
  2. Management of information related to substances available within different databases (e.g. Registration Dossiers, ECHA C&L Inventory, CLP Annex VI, Open Databases, etc.)
  3. Management of information related to products that may fall under different Regulations (REACH, Cosmetics, Agrochemicals, etc.)
  4. Un-alignment between the single Member States Dangerous Compounds Archives and between them and the ECHA Archive and future developments (e.g. article 45 of CLP Regulation)
  5. Restrictions to Access Grants to single Member States Dangerous Compounds Archives issues (e.g. not granted for Local health Agencies) and related privacy issues