Ke­mi­kaa­li­lain­sää­dän­tö – REACH-asetuksen tarkistaminen myrkyttömän ympäristön saavuttamiseksi

Komission kaikille avoimeen nettikuulemiseen jätetty vastaus.

1.6.2021

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO in Finland.

We think that the quality of chemicals safety information in REACH documentation especially with regard to environmental safety, but even to health effects, is varying and in many cases very poor.

This reflects two problems:

i) Industries and their consultants do not have competence or will to provide correct information. In some cases there is obvious abuse in using different chemical names to avoid finding the correct information from already available chemical databases.

ii) The officials of the REACH organizations are not skilled or motivated enough to locate relevant scientific information about the chemical and especially ecologic effects of the substances.

Solution is to create a scientific evaluation and comparison process of the information about toxicity and ecological impacts. It is not the best use of resources when EU industries would hire commercial consultants to even mislead the authorities and regulations. The REACH documentation for registration should not be produced by clearly industry dependent consultants, but by an independent scientific community and EU officials with the highest level research scientific skills. The data should be compared with the best international environmental and chemical authorities. This would actually reduce the bureaucracy and the costs for the companies in two ways: Academic competence is cheaper than the commercial consultants, and the process can be streamlined as an expert process without the delays of the process caused by cheating or lack of competence by the company or by the regulator. ( These problems could be easily verified by taking random 1000 REACH chemical dossiers and giving them to the top academic research groups for evaluation for correctness against the state of the art scientific information.)

The industry way of streamlining the process will likely involve weakening of the system.

The EU REACH documentation is often used as certificates for environmental safety in environmental permit processes or as evidence to avoid such processes. This is very harmful due to the presence of really substandard environmental information in substantial part of the documentation. The limits of dangerous wastes set based on the REACH packaging regulations are extremely dangerous and often directly in huge conflict with standards EU Water Framework Directive, Groundwater Directive, all dangerous and prioritized substance regulations and Mining Waste Directive. It is beyond any scientific reasoning to state that everything present as a portion under 0.1% is not dangerous. The worst substances are toxic as concentrations of million fold lower or less. Substance can be soluted from certain compositions to water even as much higher concentrations than the 0.1 %.

Defining everything not being dangerous waste as non-dangerous waste is even much worse from the point of view of the high goals set for the regulations. Therefore the system needs to be fixed based on the best science, and not the waste dumping preferences of the worst of the industries.

This statement was prepared by our senior advisor Dr. Jari Natunen.

On behalf of SUOMEN LUONNONSUOJELULIITTO

Tapani Veistola
Acting Executive Director