Essential aspects of the 2nd REACH review from the point of view of the BMU

Date: 19 December 2018


On 6-7 December 2018 the BAuA REACH congress 2018 took place in Dortmund. In the introductory presentation, Dr Axel Vorwerk, ministerial official at the Federal Ministry for the Environment, Nature Conservation and Nuclear Safety in Germany (BMU*), outlined the essential aspects of the 2nd REACH review from the point of view of the BMU.

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Among other things, he presented the positioning of the Federal Government in the priority area of data quality as follows:
Ensuring dossier conformity is a major concern for the authority.
•    The reliability of the data basis is crucial for the benefit of REACH, also for the economy itself.
•    Experience has shown that in many cases the registration data submitted are insufficient to varying degrees.
•    The BMU’s aim is for the registration dossiers for all substances to be reviewed within a manageable period of time, i.e. in the next ten years. This would require a significant multiplication of the number of dossier evaluations per year.
•    Furthermore, it must be ensured that the database is not obsolete (e.g. changed use/exposure).

Dr Vorwerk presented the following measures to improve the data quality:
•    Significant streamlining of evaluation procedures. Until now, it usually takes several years for missing data to be submitted or for erroneous data to be corrected.
•    Substantially increase the administrative resources used, including discussing how registrants should share the costs and what incentives should be put in place to ensure that information is provided in the required quality from the outset.
•    The Commission could examine measures to improve own-initiative updating under Art. 22 REACH and could also consider the question of regular updating requests.

The most remarkable statement is that the German authority aims to evaluate all REACH dossiers within the next 10 years. This is of course currently not an agreed position between member states but should raise attention in industry.

The position of Germany again emphasises that REACH is not done after the last registration deadline has passed. You should stay tuned and plan your capacities for dossier updates and substance/dossier evaluation accordingly.

To find out more details, please download the presentation (only in German available).

*Federal Ministry for the Environment, Nature Conservation and Nuclear Safety in Germany (BMU)