Document oMyxLD3kNZ2O54V61Y0bawpLD

2022/10/11 Meeting with EUROMETAUX 1. Short discussion on REACH revision: October 18th work plan EUROMETAUX: pointed out that prolonged processes provide too much uncertainty and also stops or reduces investment into the industry in EU. GRA implementation mostly likely will not much will affect metals industry. More critical might be under Authorisation but the process is planned to be revamped. COM has ability to do specific or generic restrictions (now limited for consumer side). In the past identification of substance SVHC and inclusion into the candidate list was the path to authorisation Plan is that after revision SVHC on the candidate list could undergo different processes: authorization restriction, OSH. COM hopes that there will be better discussion at the candidate EUROMETAUX: the prioritization will be limited COM: noted that there is a hope to go from individual decisions for applications to derogations of general applicability. Pointed out that clear substitution plans are needed. In reality discussion on ESU is needed for criticality for society health and safety. Pointed out that clear identification of ESU (critical uses) is needed. Idea comes from the Montreal protocol. Pointed out that when the potential to substitute is there then the substitution plan will need to be presented. EUROMETAUX: wondered whether on the discussion on ESU then the coherence with other legislation will be taken into account. Wondered when the criticality discussion will come out noted that it should be so. Pointed out that criticality discussion should come at the derogation stage (there will be discussion on criticality) and there industry will need to provide information on which uses are most critical. At the end of all the discussions additional discussion on the substitution plan with targeted actions will need to be provided EUROMETAUX: might be a good idea to look at the criteria for inclusion/ prioritisation of SVHC for regulatory action and maybe there should be an option to deprioritize due to ESU. noted that in the future that for some substances discussion for joint CARACAL-OSH / IED. Noted that there might be a bit of more flexibility for industrial/professional uses and to bring in discussion on essentiality as NGOs are more focused on GRA. Noted that the criteria for prioritization from the candidate list for further regulatory action could be revised to reflect ESU CLH