EURO COOP welcomes the opportunity for all stakeholders to comment on the future EU chemical policy - REACH.

EURO COOP has for many years called for a revision of the EU Chemicals Policy in order for it to better protect the environment and human health. The current system is not working. The control and classification of existing chemicals under the system is too slow and inefficient. As stated by the European Commission , of the 140 substances put on priority lists for high production volume (HPV) chemicals, only 11 assessments have been concluded over a 10-year time span.

The current regulatory system is based on some 60 individual pieces of legislation, which makes the procedures cumbersome. Hence, the current system does not encourage innovation and substitution.

In EURO COOP's opinion any strategy and follow-on legislation must be based on:

• The precautionary principle.
• The polluter pays principle.
• A full right to know, including what chemicals are present in products.
• A deadline by which all chemicals on the market must have had their safety independently assessed. All uses of a chemical should be approved and should be demonstrated to be safe beyond reasonable doubt.
• A phase-out of persistent or bio-accumulative chemicals.
• A requirement to substitute less safe chemicals with safer alternatives.
• A commitment to stop all releases to the environment of hazardous substances by 2020.

EURO COOP agrees that REACH must aim to close today's knowledge gap, maintain and enhance the competitiveness of European industry, protect animals, and ensure open access to key information for anyone who uses chemicals in one way or another. We believe that consumers will accept to pay the price of this system, but only if REACH at the same time aims to protect the environment and human health, particularly vulnerable groups such as children.

It should not be possible for industry to use chemicals in products where the effects to human health and the environment are not known.

Furthermore, the proposal should cover several sectors such as toys, cosmetics, clothes, detergents, paints and building materials in order not to repeat the analyses of the same substances.

More specifically, EURO COOP has the following comments:

Scope of Authorisation:

EURO COOP is happy to see that the scope of authorisation will not only cover 'category one' chemicals (carcinogenic, mutagenic or toxic to reproduction (CMRs)) - those proven to affect human health, 'category two' chemicals - those where there is reasonable proof that they affect human health, and persistent organic pollutants (POPs). But that the Commission has decided also to add persistent, bio-accumulative and toxic chemicals (PBTs), very persistent and very bio-accumulative substances (vPvBs), and endocrine disrupters. EURO COOP has long argued for endocrine disrupting chemicals to be included.

EURO COOP, furthermore, believes that a mechanism has to be developed on how to deal with the potential of synergetic effects from a mix of chemicals. If not, there is a risk that chemicals will be authorised due their PNEC (potential no effect concentration), despite the fact that there would be a problem if a number of chemicals appear as a "cocktail" in the air, the sewage sludge, water or soil.

Information:

In EURO COOP's opinion REACH will secure a more predictable regulatory system instead of the current ad hoc case-by-case approach.

However, EURO COOP would like to stress the need to include in REACH the necessity for a simple and comprehensible labelling system. The consumers have a right to know the constituents of products in order to be able to make an informed choice.

Besides, retailers will need the information too in order to be able to advise their customers/consumers. Currently, there is no system in place to secure the flow of information from producers to downstream users and consumers.

Nevertheless, labelling must not be used by industry to put the responsibility on consumers. Industry must remain responsible for the content, and correct use and disposal of their products.

However, one thing is labelling products another thing is for the labels to be comprehendible for all users/consumers. Therefore, educational measures, such as information campaigns and leaflets, should be taken in order for the consumers to better understand the problems in relation to chemicals.

Furthermore, the current proposal for REACH does not give any deadline for the Agency to publish information in its public database, which does not facilitate the flow of information nor enhances transparency.

Precautionary Principle and Principle of Substitution:

EURO COOP also believes that the precautionary principle and the principle of substituting for safer alternatives need to be further developed and clearer expressed in the proposal. The system must not become a license to continue using risky chemicals. The intention must be to ban risky chemicals except in those cases where it can be proved that there is a public need and no safer substitute. A pre-requisite for this is to safeguard the safe disposal of packaging and product waste.

In this respect, EURO COOP would like REACH to address the problem on how to avoid that banned chemicals or products containing the banned chemical/chemicals are not dumped on retailers in order for manufacturers to get rid of them before the ban enters into force. A system needs to be put in place to avoid this.

Imported Goods:

It is also necessary to strengthen the proposal in terms of how to deal with chemicals in imported goods. As the proposal stands now it is too weak compared to the requirements for domestic products.

Evaluation:

In order for the system to work, it is necessary that deadlines are set for evaluating how well it is functioning and if it meets the aims set out. It may also be necessary to adjust or change some of the original aims due to new scientific evidence of safer alternatives or harmful effects of a chemical or a combination of chemicals to human health and/or the environment.

In addition, timetables for authorisation, non-authorisation or use restrictions of the various kinds of chemicals should be included in order to have an optimal system.

Research and Development:

EURO COOP would also like to see financial means allocated to further research and development of safer alternatives.

Agency:

Regarding the Agency's expert Committees and the Management Board, EURO COOP believes that all stakeholders must be represented on those on an equal footing, from the producer to the final consumer.

In conclusion, EURO COOP would like to reconfirm its support to a new EU chemicals policy. We do not wish to see any further delay in putting forward the European Commission's proposals.