ChemSec guides EU on REACH reform and highlights packaging importance

ChemSec is advising the European Commission (EC) on simplifying the EU’s Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation and PFAS clarification. The EC’s president, Ursula von der Leyen, recently announced that she aims to simplify the regulation.

ChemSec’s chemicals policy advisor, Sidsel Dyekjær, tells us more about the secretariat’s suggestions and their potential impact on the packaging industry. 

Currently, packaging is covered by REACH Article 33, which says that suppliers must inform their customers about Substances of Very High Concern in the products. 

“The biggest change, we wish to see, is an efficient implementation of the GRA [Generic Risk Assessment] concept in the REACH revision,” Dyekjær tells Packaging Insights.

ChemSec says that simplifying REACH does not have to be complicated. One key aspect of the Chemicals Strategy for Sustainability, the GRA, can phase out the most harmful substances.

The approach has delivered major health benefits for EU citizens in recent decades, according to the non-profit environmental organization. “Merely following through on the plans already laid out in the strategy can make a huge difference,” it says.

Packaging is important for REACH, being a high-volume product group with significant consumer exposure.Dyekjær says that packaging is important for REACH since it is a high-volume product group with significant consumer exposure. “When the GRA is implemented in REACH, it should include packaging as an important article group.”

A different ban than for other chemicals

The GRA approach is detailed in the former Commission’s Chemicals Strategy for Sustainability (CSS). 

“The GRA approach is a very important way to ensure that consumers are not exposed to the most harmful chemicals, such as those that harm our hormone system, our fertility or cause cancer,” says Dyekjær.

“The CSS made it clear that these chemicals are so hazardous that it would not be reasonable to let consumers take the risk of being exposed to them. Thus, they should be subject to a more automated type of ban than other chemicals, where complicated assessments of exposure and risks must be conducted before a ban can be implemented.”

“This is particularly important since we know that many risk assessments in the past have underestimated the risks,” she adds.

With the Generic Risk Approach, ChemSec says the industry would have a quicker procedure in the REACH toolbox, one that can “truly” improve the system. 

“Not only would the REACH regulation become simpler, it would also lead to a heap of other benefits,” it says.

ChemSec provides four more ways in which extending the use of restrictions through the Generic Risk Approach would simplify REACH and make it more effective:

• Save time and money.
• Enable a circular economy.
• Unlock the market for safer alternatives.
• Create a level playing field.

When asked how these changes can impact the packaging industry, Dyekjær says that the industry would have to seek information in the supply chain and ensure that its packaging and other articles comply with the new provisions. 

“It remains to be seen how these would play out for packaging,” she adds.

“In general, you can say that when new legislation comes into play, this may benefit some companies and make life more difficult for others. Those companies who can manage the change of today will have the market of tomorrow.”