Presentations of the Commission to the CARACAL

Analysis of the Commission’s REACH revision plans after the April 2025 CARACAL meeting.

Background

• On April 3, the Commission presented their REACH proposals to the CARACAL (Competent Authorities for REACH and CLP). All bureaucratic and highly damaging tightening measures from the original Chemicals Strategy for Sustainability (CSS) are included. "
• Although industry commissioner Stéphane Séjourné and environment commissioner Jessika Roswall have said they’re aiming to simplify the rules in order to help relieve the administrative burden for Europe’s chemicals industry, the Commission and MS carry on without taking the new global political and economic situation into account.

VCI-Evaluation

• Particularly problematic are:
  • Limiting the validity of registration to 10 years. Companies need to register again or renew the registration, eventually pay (higher) fees again and fulfill higher data requirements. This establishes a fee generating bureaucratic perpetuum mobile.
  • Overall higher data and information requirements in each of the REACH processes.
  • Introduction of the “Generic Risk Management Approach” (GRA), the Mixture Allocation Factor (MAF) >1,000 t/a and the Essential Use Concept to regulate chemicals — which means moving towards regulating substances based on their inherent hazardous properties, rather than on a substance-by-substance, use-specific basis.
  • Notification and possible registration of polymers. This would result in extremely high additional burden for industry.
  • "Upfront Analysis and Discussion of Regulatory Options" (proposed by Cefic in its 10-Point Action Plan) are mentioned as a "fig leaf". Compared to the tightening measures under discussion, however, this is rather worthless.

VCI-Conclusion

• The proposals undermine scientific risk assessment and are at the expense of chemical diversity, innovation, competitiveness and planning security and could unduly reduce the participation of companies, e.g. in restriction procedures.
• All proposals presented by the Commission in CARACAL automatically mean much more bureaucracy, higher costs and planning uncertainty for companies.

Questions for the Commission

• Where are the announced simplifications and the reduction in bureaucracy for companies?
• How have the effects on SMEs and the German Mittelstand been taken into account?
• How have the effects on resilience, chemical diversity, competitiveness and innovative strength been taken into account?