The American Chamber of Commerce to the European Union (AmCham EU) has proposed critical recommendations to the European Commission to simplify the REACH Regulation. This reform aims to reduce regulatory burdens on businesses, foster competitiveness, and align chemical safety laws with scientific risk assessments. The move is vital as the EU's chemicals industry underpins 96% of manufactured goods and plays a pivotal role in delivering the Green Deal goals.
Why Simplifying REACH Matters
With the European Commission planning a new Chemicals Industry Package for 2025, AmCham EU emphasises the importance of simplifying REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals) to address economic and geopolitical challenges. The proposed reforms could remove investment uncertainties, reduce regulatory redundancies, and strengthen Europe's competitiveness in industries ranging from pharmaceuticals to renewable energy.
The 2018 and 2020 reviews of REACH highlighted the EU's leadership in chemical safety but acknowledged areas for improvement. According to AmCham EU, overcomplicated and inconsistent regulations often hinder investments, creating unnecessary barriers across the chemicals value chain.
Key Recommendations from AmCham EU
AmCham EU’s position paper lays out five core strategies to streamline REACH:
1. Science-Based Decision Making
Policymakers should rely on risk assessments and avoid overgeneralising substances, such as PFAS (per- and polyfluoroalkyl substances). AmCham EU recommends using hazard data and chemical properties instead of excessively broad groupings to ensure targeted regulations.
2. Regulatory Predictability
Clear and consistent regulatory pathways are essential to attract investments. AmCham EU suggests mandatory Regulatory Management Options Analysis (RMOA) for newly identified substances of very high concern (SVHCs). This approach would prevent overlapping restrictions and increase confidence in regulatory decisions.
3. Aligning REACH with Other Legislation
The Commission must ensure that REACH remains the primary framework for chemical safety in the EU. AmCham EU warns against introducing redundant definitions and requirements in emerging regulations, such as those under the European Green Deal or Ecodesign for Sustainable Products Regulation.
4. Strengthening Enforcement
To address unfair competition from imported goods, AmCham EU proposes elevating the ECHA Enforcement Forum to a committee-level authority, on par with the Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC).
5. Simplifying Data Requirements and Promoting Digitalisation
The current data requirements for registering chemicals should better reflect exposure risks and reduce unnecessary animal testing. AmCham EU also advocates for digitised supply chain communication, such as QR-coded safety sheets, to streamline compliance and updates.
Balancing Safety with Competitiveness
The chemicals industry is integral to achieving the EU’s climate and digital ambitions, including the Green Deal. Simplifying REACH would foster innovation while ensuring safety standards remain robust. "By addressing unnecessary complexities, policymakers can unlock the full potential of Europe’s chemical sector," the position paper states.
AmCham EU’s recommendations to simplify REACH present a pathway for balanced regulations that protect human health and the environment while reducing burdens on businesses. With the Chemicals Industry Package set for 2025, the European Commission has a pivotal opportunity to create a more predictable and investment-friendly regulatory framework.
