EuroWindoor published its feedback on Inception Impact Assessment on the revision of REACH Regulation

On June 1st, EuroWindoor had the opportunity to give feedback on the consultation of the revision of REACH for its SMEs of the European window, door and façade sector. EuroWindoor welcomes many revisions proposed, but sees further improvement in certain areas, especially at the communication in the supply chains.

REACH, a part in the Commissions European Green Deal strategy, was lastly evaluated in 2018 resulting in many opportunities for improvements. Many of those improvements are in the administrative field like the initiative to streamline procedures and to accelerate decision-making. Besides this the reformation of the restrictive process was initiated were EuroWindoor hopes a more dialogue-based process will be implemented to ensure an easier access. Even more EuroWindoor supports the initiative to improve enforcement in Member States to ensure a level playing field across Europe.

The latest REACH Review identified the communication in the supply chains as inefficient and therefore the commission wants to improve safety data sheets. EuroWindoor agrees on the improvement of communication in the supply chain, but is in favour for a better solution. SMEs of the sector are at the end of a very difficult and complex supply chain, often, with little chemical knowledge. This puts them at a position were they are dependant of their suppliers information and without possibilities to control the completeness of the received information. Instead of overworking safety data sheets EuroWindoor wants a guidance in layman terms for SMEs and additional information like intended uses for SVHC of the candidate list. This gives SMEs more tools to communicate with their suppliers and identifying information gaps.

EuroWindoor further addressed the difficulties with recyclate coming from recycling in the REACH framework which is relevant in the context of circular economy. A steady and uniform framework is needed.

Lastly EuroWindoors indicates its support for reforming the authorisation process, but warns against giving national authorities too much responsibility for national authorisations which could lead to trade restrictions and market distortion.
EuroWindoor feedback on Inception Impact Assessment revision of REACH

[Here  you will find all position papers / publications]

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