First REACH list to be short but regularly updated

Asked whether the list was too short, Geert Dancet, executive director of the European Chemicals Agency (ECHA), said it was "relatively short", but this was because the process is just starting and everybody is struggling to establish and become familiar with new heavy administrative procedures and dealing with scarce resources available for testing chemicals. He also said that working procedures needed streamlining as otherwise new administrative burdens could "overload the system". He did not comment on the SIN list.

All chemicals on the SIN list "are dangerous and deserve to be on the candidate list of REACH," noted a member of the list's advisory committee Daryl W. Ditz, a policy advisor at the Chemicals Program Centre for International Environmental Law (CIEL)  in the US.

Ditz said the aim of the list is "to help provide guidance to businesses so that they can make wise choices" and start substituting dangerous chemicals before regulation. The list gives downstream chemical users (companies making automobiles, electronics, buildings, consumer products, toys, food, etc.) "an early warning" and thus time to find their own solutions and new suppliers "who give them something safer". Seeing the list, a smart company will start making plans because using these chemicals in ten years "will not be good business," he added.

Ditz also underlined that the first REACH candidate list was about chemicals defined by their properties: if they cause cancer, birth defects or are persistent, "it does not mean they are all banned, just that they are identified". According to him, diverse companies and NGOs agree that the most harmful chemicals need to be substituted. But it is normal for companies to be cautious about substitutes, because before getting rid of one substance, they need to be sure about the safety of the other, Ditz concluded.

"Companies closest to the end-user and consumer know that things have to change. They have already turned to public interest organisations for advice," agreed ChemSec senior policy advisor Nardono Nimpuno, adding that anticipating consumer demand for safer products had already made some companies both more innovative and more competitive.

Cefic, the European Chemical Industry Council, noted that the responsibility for identifying substances of very high concern in REACH "lies exclusively with ECHA and the EU member states". It therefore believes that any list published outside the official identification process "might be confusing and not helpful in establishing REACH as the centrepiece of the chemicals legislation".

"The 'SIN list' is a proposal from a specific interest group and not part of the overall REACH legal design. It could potentially contribute to confusion throughout the value chain," stated Cefic.