On 2 February 2022, the European Chemicals Agency (ECHA) launched a public consultation on its proposals to include lead metal, in addition to seven other substances, to Annex XIV of REACH, the list of substances subject to authorisation. The European Commission has opened a call for information in parallel on the possible economic, social, health and environmental impacts (costs and benefits) of the proposals.
Companies have from now until 2 May 2022 to provide comments to the consultation and call for information to help inform the decision on the proposal.
Why is it important to participate in the consultation?
Put simply – the more information ECHA has, the more informed its decision-making process will be. While REACH registration dossiers are the main source of information for ECHA's assessment, these may not be up-to-date, do not necessarily cover all uses within the scope of authorisation or possible exemptions from the authorisation requirement, nor will they contain information on the structure and complexity of supply chains or challenges associated with substitution. It is just as important to provide information on the possible socio-economic consequences of including lead in Annex XIV.
If you don’t respond, then your uses or concerns may not be considered. Adding lead metal to the Authorisation List means your company may face a costly authorisation process or be forced to cease use.
TSG Consulting can help
Led by Sue Bullock, Head of Industrial & Specialty Chemicals (ISC), TSG’s experienced REACH consultants can support you through this public consultation process and beyond. We can help you:
- Understand how and when you might be impacted
- Outline the health, social and economic consequences of the proposed inclusion of lead on the REACH Authorisation List for your specific use(s)
- Map and manage concerns through your supply chain, from supplier to customer
- Develop a practical roadmap for REACH compliance, including assessing potential substitute products
- Help identify the different options and support you in choosing the preferred one
- Participate effectively in the public consultation process and call for information, and track policy and regulatory developments
- Prepare you for the next steps, including authorisation listing
If you’d like to have an informal chat with our team, please get in touch at [email protected]