Document Z4m8gmXz437QmrL7K9Op26ZJ7
Questions for ECHA Secretariat
Questions on timing
Can you give us your most realistic estimation of the timing for the final combined RAC/SEAC report, as we see more and more National bans popping up and they jeopardise the single market.
What is the timing of the second 60-day consultation?
Questions on Information provision
What kind of information needs to be provided in the second consultation? As the consultation time is very short, it would be very helpful if you shared any information requested well ahead of the start of the second consultation.
At the start of the second consultation, the final RAC opinion and the SEAC draft opinion will be published. Will the complete SEAC draft opinion covering all uses be available at that time as ECHA covers the different uses in sequence?
Can ECHA publish the updated Annex XV report and the background document a few times during the process? The original proposal would have an extremely high impact on several sectors. Industry is still very concerned. We have done our very best to provide input but we still do not know if that had any effect or that we still have to fear the survival of our companies. It would be highly appreciated if a response could be published. Perhaps to start with general things like the DS opinion on an exemption for articles already on the market, a spare part exemption, the transition period.
Is there a possibility for industry to hand in data/ new studies prior to the public consultation of the draft SEAC opinion?
Questions on procedure
How many observers can join a SEAC meeting? How to make sure that all stakeholders are represented?
Why would it not be possible for more delegates attend the RAC/SEAC meetings, even if they could only be silent attendees?
Is it still planned to develop an opinion for all sectors before submitting the dossier to the Commission? Or will the dossier be split and will the opinion of the first set of sectors be sent to the Commission and a second part later?
Currently the documents from RAC and SEAC are shared only with a very small group of people that are bound by confidentiality. Would it be possible to allow a broader distribution of these documents or publication with the agenda on the RAC and SEAC websites?
Who has the final decision on determining whether there are suitable alternatives or not and according to which criteria they will be accepted?
Who will validate the technology readiness level (TRL)? What criteria will determine whether the technical, social, environmental and safety performance of an alternative is the same?