On 3-4 April 2025, during the 54th Meeting of Competent Authorities for REACH and CLP (CARACAL), the European Commission presented elements being considered for the revision of the Regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).
APPLiA, representing home appliance manufacturers in Europe, welcomes the ambition to simplify, modernise and strengthen the enforcement of REACH. Our industry, which supports over 1 million jobs and plays a crucial role in driving innovation and economic growth, contributing an added value of €79 billion to the European Gross Domestic Product (GDP), relies on chemicals for durability and circularity.
To ensure a high level of protection of human health and the environment, key initiatives like the revision of REACH, a cornerstone of European chemical policy, should better consider the specificities of the home appliance sector. With this paper, we aim to contribute to the discussion and provide our input on the proposed changes.
We firmly oppose the shift towards a hazard-based approach with the extension of the Generic Risk Approach (GRA). Chemical assessments should continue to be guided by the concept of safe use and the revision of REACH should rather uphold and strengthen a risk-based approach.
A risk-based approach, which considers the hazard of a substance and the likelihood and level of exposure as well as the application, is more effective and scientifically sound than a purely hazard-based approach, which focuses solely on the inherent properties of a substance without considering real-world exposure scenarios.
APPLiA expresses strong reservations about the use of the Essential Use Concept (EUC) based on the Commission Communication C/2024/2894 of 26 April 2024, and recommends that its implementation should be avoided. We are concerned that the EUC,
intended to mitigate challenges from extending the GRA and shifting to hazard-based management, will instead lead to unsubstantiated, oversimplified assumptions.
We strongly advocate for preserving the integrity and central role of the established risk-assessment procedures within the REACH framework. We believe that decisions on chemical restrictions or authorisations should continue to be based on thorough, case-by-case scientific analysis as currently mandated. Regarding potential use categorisations, such as 'essential' or 'non-essential', it is important that these do not pre-empt or replace the fundamental risk assessment. Should the concept of essential use be considered further in the REACH revision, we recommend its application should follow, and potentially supplement, the risk assessment process, rather than substituting it.
Furthermore, we find the EUC's grouping approach, based on an unmanageable collection of substances, problematic. Additionally, we estimate that the Communication of the Commission will not lead to clear decisions about essential or non-essential uses. In contrast, the concept is missing clear procedures and responsibilities and is too vague and abstract for providing guidance. Examples are only touching very simplified cases and leaving room for ambiguous interpretation of more complex and difficult situations. Hence, alternatively we recommend grouping by shared properties.
In cases where it is justified in order to prevent regrettable substitution, we recommend adopting a multi-faceted methodology to group substances: grouping should be fundamentally based on toxicological properties and other relevant profiles, not solely on structural similarity.
We support the concept of grouping substances for evaluation but stress that the grouping methodology should be comprehensive and scientifically sound. We believe that relying solely on structural similarity is inadequate and advocate for considering a range of relevant factors.
We propose a grouping methodology based on a comprehensive set of profiles, such as shared (eco)-toxicological and physico-chemical properties, similar toxico-kinetics, environmental fate and behaviour, and common adverse outcome pathways, rather than solely on structural similarity. This approach would lead to more practical, scientifically sound, and enforceable regulatory measures.
However and in contrast to the above, we are very skeptical to extend the GRA for restrictions generically to all consumer goods. Considering the vast variety of products, ranging from substances/mixtures, textiles, to toys or household appliances, APPLiA believes that at least a differentiation taking into account real exposure would be required.
We firmly believe that gathering information on use, exposure, and available alternatives at an early stage will enable more precise and effective regulatory measures. Before any restriction measure is introduced, available alternatives should be proven to be safe and undergo the same risk assessment as the substance that is going to be restricted to avoid regrettable substitution.
When considering substitution, APPLiA states that risks to human health and the environment, and technical and economic feasibility and availability should be considered. This includes technical role and performance requirements like quality and durability, as well as economic availability, such as volumes, choice of suppliers, patent rights, and price.
We welcome the consideration of a Risk Management Option Analysis (RMOA), that should be a mandatory step before initiating any restriction or authorisation procedure under REACH. We also support that the European Commission is considering a changed role of the Substances of Very High Concern (SVHC) candidate list to become a tool to prioritise regulatory action in general, instead of being the first step to authorisation only.
APPLiA advocates in favour of digitalising and simplifying supply chain communication but underlines the necessity to better consider the specificities of downstream users like the home appliance sector.
Transparent communication in the supply chain, ensuring that information on chemical content is readily available, is fundamental. However, the complexity of supply chains in obtaining necessary information for product safety and compliance should be recognised and adequately tackled. The burden of proof for demonstrating safety should lie on the full supply chain.
Suppliers should provide relevant information, preferably through a harmonised system, to facilitate easier compliance. In consideration of potential confidentiality issues, we put forward the suggestion of having sensitive data anonymised externally preceding its disclosure.
The digitalisation of Safety Data Sheets (SDS) and the use of the Digital Product Passport (DPP), as proposed by the European Commission, should therefore carefully seek a balance between transparency and practicality in supply chain communication.
APPLiA welcomes the objective to strengthen and improve the effectiveness and efficiency of control systems across the EU, contributing to a level playing field. We call for stronger and more harmonised market surveillance activities across EU Member States, including robust controls on imports from third countries to prevent the entry of non-compliant substances like PFAS into the EU market. We advocate for a focus on product testing to ensure compliance with Regulations and to prevent ‘free riders’ who undermine fair competition.
The European Commission’s proposal to create a European audit capacity and to develop market surveillance requirements for Member States' official control systems to the whole scope of REACH obligations echoes our belief that consistent and rigorous market surveillance is key to ensuring a level playing field for economic operators and for protecting consumers and the environment. Market surveillance authorities should be provided with adequate resources to effectively carry out their duties, including conducting product testing, verifying compliance and issuing penalties for violations.
The European Chemicals Agency’s (ECHA) persistent shortages in staff and funding are showing up as procedural failings that weaken its ability to produce sound scientific evaluations, plainly illustrated by the ongoing per- and polyfluoroalkyl substances (PFAS) restriction review, because the Agency is not able to maintain basic norms of stakeholder involvement and record‑keeping. In this dossier, for example, no structured system exists to register, group, or respond to observers’ questions. Further, there is no sign that external input is taken into account in draft opinions, and neither draft minutes nor recordings are shared, allowing essential discussions to disappear from the official record. Taken together, these flaws seriously call into question whether ECHA is currently able, and would be able, to meet its expanding responsibilities with the diligence and analytical rigour that EU chemicals policy expects.
APPLiA is committed to working constructively with the European Commission and other stakeholders to ensure that the REACH revision process results in a robust, effective and implementable regulatory framework. We believe that a balanced approach that considers the needs of industry, the environment and consumers is essential.
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