Risk management under REACH Requirements of technical and organisational guidance for producers, importers and downstream users

In: ELNI review, p. 7-15

Abstract

The success of REACh will depend on whether or not the actors are willing and able to adopt the roles allocated to them under the new regime. Yet it would be naive to assume that the simple fact of enacting the Regulation will be sufficient to effect the necessary changes in the behaviour of the responsible parties. Within this context, a study on behalf of the German Federal Environmental Agency (Umweltbundesamt – UBA) was performed. The study's initial hypothesis was that support - in the form of (technical and organisational) guidance specific to each type of economic actor - can help to push forward the necessary innovation and co-operation processes to implement REACh in the intended way. Thus, transaction costs for each actor can be kept to a minimum and obstacles overcome. This also supports the central, structural objective of REACh to establish a "learning system", particularly with regard to the interaction occurring between the producers and users of industrial chemicals. To this end, sufficient regulatory (dis)incentives are essential. For this reason, the question of possible amendments to the current draft of the Regulation was also addressed.