REACH: substance evaluation

REACH on cruise control: ECHA publishes its first Community Rolling Action Plan

In a nutshell

Under REACH, companies have the responsibility of collecting information on the properties and the uses of substances that they manufacture or import and assessing the hazards and risks. This information is then included in the registration dossier, submitted to ECHA. ECHA and the Member States evaluate the information and, based on the available information, select the substances that are to be further evaluated. A Community Rolling Action Plan (CoRAP) tables a calendar, mentions the concerns that lead to the selection of the substance and appoints a responsible Member State for each evaluation.

The first CoRAP

On February 29, ECHA published on its website thefirst CoRAP containing the list of substances that will go through the substance evaluation process. Of all proposed substances in the draft plan (see our earlier Bulletin item on this), the Member State Committee retained 90 of the initial 91 proposed substances.

Calendar & Content of the Program

This first CoRAP stretches over a period of 3 years (2012-2014). The substances subject to immediate evaluation are listed for the first year of the plan. For 2012, 36 substances will be evaluated. The remainder have been listed for 2013 and 2014.

The content of the program is flexible to some extent: after the first year, the plan can be updated to include substances for the following year as well as any revision to the substances that were included in the second and third year of the original plan. Throughout the whole action plan, a Member State may even notify at any time that it has information suggesting that a substance is a priority for evaluation, even though it is not included in the CoRAP list: in these situations, the CoRAP may be amended to include this substance. Therefore, the total number of the substances to be evaluated in 2012, 2013 and 2014 could eventually be (much) higher then the scheduled 90 items.

As of 29 February, the respective Member States have one year to evaluate substances specified for the year 2012 and, where justified, to prepare a draft decision requesting the registrant(s) to submit further information to clarify any possible risk. The decision will be taken by ECHA after consultation of the Member State Competent Authorities and the MSC, or by the European Commission if there is no unanimity at the MSC.

A first update is scheduled for 2013.