JBCE's Environment & Energy Committee contributed to the consultation on the proposal for the ATRm for UK REACH

25/07/2024

On 25^th July 2024, JBCE contributed to the consultation on the proposal for the ATRm for UK REACH.

JBCE disagrees with the proposal to significantly reduce the hazard information and to enhance what information on ‘use and exposure’ in ATRm.

Confirmation of hazard-related endpoints is still necessary for hazard classification, and there are also concerns that proper hazard assessments may not be carried out for substances with complex endpoints. UK REACH registrants will need to purchase the rights to use the full report to confirm hazard-related endpoints from the lead registrant or their consortium under EU REACH. Therefore, we do not expect the revised hazard data requirements to reduce costs for businesses.

For substances with complex supply chains and multiple uses, it is not easy to gather the downstream user use and exposure data required for a CSA. Particularly, if ORs are required to be appointed in the UK, it will be challenging for appointed ORs or suppliers outside the UK to undertake these tasks.

For more information please contact:

Masakazu Shimosawa, Policy Manager, Environment & Energy

Tetsusaburo Miura, Policy Manager, Environment & Energy

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