Document o99v46OKM9ooBnZR2qLyoyqpr
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Meeting with Essential Use coalition
When: 4 June 2021, 09:45 Where: Microsoft Teams Participants Eosontiol UsesCaaiition.EUROFER
ickel Institute Eurobat pthin
Nederland (ION; Vereniging Industrieel Opperviaktebehandelend
Commission istoScheiber director GROWF
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The EssentialUse Coalition underlined the Importanocef
hazardous substances for uses in a very wide range of products,
including for products which can promote the objectives of the
Green Deal,
Intheir view, essential use assessment in awide range of
products and throughout whole supplychains would bea
lengthy and potentially bureaucratic process, creating
uncertainties for industry
Aplying
generic approach torestrictions automatically and in a
too widearea might be counterproductifvoer sustainable
development (e.g. durability, circularity, energy and climate
aspects
Theyconsideredthatthare was a neteo d excludesafe uses
(where there is no rik) from the scope of such restrictions.
Otherthwisicosuled lead to banning safe productsifthey are.
not considered essential
They presented a flow-chart showing how in their view the
practical application of the essential uses concept could work
They supported the use of Regulatory Management Options Analysis (RMOA)
They asked about the Commission's discretion in the future restrictions tosetthe scope of such restrictions and whether there wouldbe ascientific assessment by ECHA's committees and public consultations, (Details see attached presentation)
The Commission services explained the reasoning for the extension of the existing generic risk approach to further hazard classes and uses.
They underlined that within the generic risk approach there needsto be adifferentiation between substances and mixtures on the one hand and articles on the other hand, which might not allbeaddressed in the same way and at the same time. Also, not every use would undergo a separate essential use assessment.
+ One of the purposes of the essential use concept is to facilitate. the derogations for harmful chemicals, so that they can be used `when essential to society, in particulator achievethe Green Deal goals.
An effective, efficient and practical way of integrating essential use considerations into decision making will be needed, taking into account the experience from the currentsystemalready in REACH andsimilar existing systems (existing generic restrictions. for CMR in REACH, RoHS, Toy Safety Directive etc). The discussion is stillat an early stage and many details will need to be worked out. The Commission explained the next steps in the discussion and in the legislative processteos revise REACH and other legislation in which the concept will also be integrated. `Theyalso recalled the ongoing work by five Member States on a restriction of PFAS substances iall except essential uses.
The future REACH authorisatainodn restrictions system, including theway authorisations/derogations will be granted, is also part of the planned REACH revision. It is difficult to predict the exact operation of the restriction and derogation system in future. However, its clear that there will be some sort of scientific assessment by the Commission and/or ECHApriorto proposing future restrictions and in particular for derogations. from such restrictions.