10 years in: time for ECHA to disseminate strategic information to empower third parties

The report argues that while ECHA has made some progress in transparency, it continues to withhold critical data on tonnage bands, exposure scenarios, and non-compliant companies, thereby hindering the ability of civil society, investors, and innovators to promote safer chemical alternatives.

• ECHA fails to publish individual tonnage bands for registrants, instead providing only aggregated data, which the report argues is a restrictive and incorrect interpretation of Article 119(2)(b) of REACH.
• The agency does not systematically publish full exposure scenarios, which are essential for understanding real-life risks and risk management measures, often citing poor data quality as a reason for withholding them.
• ECHA lacks transparency regarding the justification for granting confidentiality claims, with the report noting that 85% of such claims are accepted without public rationale.
• Information on substances of very high concern (SVHC) in articles is disseminated in a generic format that prevents consumers and investors from identifying specific products or companies.
• ECHA's 'completeness check' for registration dossiers was historically flawed, relying on an automated system that only verified the presence of characters rather than meaningful data, leading to potentially unlawful registrations.
• There is a lack of transparency regarding non-compliant companies in the dossier evaluation process, as ECHA does not publish the names of companies that fail to remedy non-compliance by the deadline.
• In the authorisation process, ECHA is criticized for redacting key information and for a perceived bias in the Socio-Economic Analysis Committee (SEAC), which tends to dismiss third-party evidence of alternatives while accepting applicant claims.
• ECHA does not systematically disclose the identity, location, or specific quantities of substances of very high concern used by downstream users, despite requests and legal challenges.
• The restriction process is hampered by a lack of transparency regarding the criteria used to assess public consultation contributions, with a tendency to favor derogations that narrow the scope of restrictions.
• The Classification and Labelling (C&L) Inventory suffers from divergent self-classifications, and ECHA has not yet made the names of notifiers public to facilitate harmonisation.

APA

Bernard, A., & Roger, D. A. (2017). 10 years in: time for ECHA to disseminate strategic information to empower third parties. ClientEarth. https://www.clientearth.org/media/r2momo10/10-years-in-time-for-echa-to-disseminate-strategic-information-to-empower-third-parties-ce-en.pdf

Chicago

Bernard, Alice, and Dr. Apolline Roger. 10 years in: time for ECHA to disseminate strategic information to empower third parties. ClientEarth, 2017. https://www.clientearth.org/media/r2momo10/10-years-in-time-for-echa-to-disseminate-strategic-information-to-empower-third-parties-ce-en.pdf.

Wikipedia

{{cite report |last1=Bernard |first1=Alice |last2=Roger |first2=Dr. Apolline |title=10 years in: time for ECHA to disseminate strategic information to empower third parties |publisher=ClientEarth |date=18 December 2017 |url=https://www.clientearth.org/media/r2momo10/10-years-in-time-for-echa-to-disseminate-strategic-information-to-empower-third-parties-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{bernard2017years, author = {Bernard, Alice and Roger, Dr. Apolline}, title = {{10 years in: time for ECHA to disseminate strategic information to empower third parties}}, institution = {ClientEarth}, year = {2017}, month = dec, url = {https://www.clientearth.org/media/r2momo10/10-years-in-time-for-echa-to-disseminate-strategic-information-to-empower-third-parties-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }