Memorandum to Czech Presidency and Ten Test - EEB

EEB Memorandum to the Czech EU Presidencyshould be substituted with safer alternatives (“candidate list”). Customers andconsumer may request to receive information within 45 days of receipt of articlescontaining those substances in a concentration above 0,1%. This historicinformation requirement should ensure safe use of the article and as a minimumprovide the name of this substance.Only the Member States and the Commission can make proposals to ECHA tonominate additional substances. So far the European Commission hasearmarked only 5 substances. Austria and Norway also indicated that they willsubmit a dossier on a further 2 substances in total (tris phosphate and arsenic/itssalts).ECHA indicated that any other dossiers submitted by May 2009 could beprocessed at the same time as the 5 dossiers identified by the EuropeanCommission.Regarding the final list of substances to be put on Annex XIV (authorisation)ECHA will have to make a draft recommendation on which the Member Stateswill issue an opinion in May 2009. A final recommendation will be submitted tothe Commission by June 2009 and a final decision will be taken through theregulatory committee procedure with scrutiny, probably in autumn 2009,specifying application, sunset dates and eventual exemptions.For EEB the first candidate list is a welcome start, but is a drop in the oceanwhen compared to the hundreds of well-known dangerous substances present inevery day products. Member States and the Commission have failed to make thelist as comprehensive as possible. An NGO coalition coordinated by theInternational Chemical Secretariat has launched the “SIN list 1.0”, which containssubstances carefully identified by independent toxicologists that fulfil the officialREACH criteria of SVHC based on publicly available scientific research. EEBhopes that this list will be used as a starting point for the next recommendationsfor inclusion in Annex XIV.It is clear that Member States and especially the presidency have a very crucialand active role to play during this process. The outcome will determine thecredibility of the REACH authorisation system in effectively reaching its objectiveof substituting hazardous substances with safer alternatives.EEB maintains that the list of SVHC recommended for substitution should bemore representative of the hundreds of hazardous chemicals currently known,therefore we ask the Czech Presidency to:- Lead by example by submitting dossiers on hazardous substances forauthorisation and call upon Member States and the Commission to makethe first list as comprehensive as possible, using the SIN list as thestarting point.43