Comment

ATLA 31, 353–364, 2003 353CCoommmmeennttA Critical Assessment of the European Commission’sProposals for the Risk Assessment and Registration ofChemical Substances in the European UnionRobert Combes, Jennifer Dandrea and Michael BallsFRAME, Russell & Burch House, 96–98 North Sherwood Street, Nottingham NG1 4EE, UKSummary — In May, 2003, the European Commission published detailed proposals relating to its 2001White Paper – Strategy for a Future Chemicals Policy. The White Paper described a new registration systemcalled the REACH (Registration, Evaluation and Authorisation of Chemicals) system, for both new and exist-ing chemicals. Subsequently, these detailed proposals were available for an eight-week consultation periodfor stakeholders to voice their views and concerns. In this paper, we describe our reactions to the Com-mission’s more-detailed proposals. These include the creation of a European Chemicals Agency to imple-ment the REACH system in conjunction with Competent Authorities (CAs) in Member States and theCommission itself. Unfortunately, many of our concerns and suggestions, previously voiced and sharedwith several other key stakeholders, remain unanswered, but are as relevant as when the White Paper waspublished. In particular, we are concerned about the lack of a clear and coherent strategy. There is no guid-ance for registrants on ...