REACH 2 - Shift the trend

ClientEarth proposes four key reforms to the REACH regulation: requiring full data for market access, simplifying and accelerating the restriction of hazardous chemicals, incentivizing companies that transition to safe alternatives, and enhancing enforcement and transparency to ensure compliance.

• Current REACH registration data is often incomplete or inaccurate, leading EU institutions to spend significant resources on separate data collection. Reform should shift the standard from "some data will do" to requiring "truly full data to be allowed to market," including missing data for endocrine disruptors and PMTs.
• The scope of chemical registration is too narrow, leaving significant gaps in knowledge regarding polymers and low tonnage substances that need to be addressed.
• Existing restriction processes are inefficient; the easiest process (Article 68.2) is underused, while the most common (Article 68.1) is overly burdensome. The document proposes a common goal for all processes: the "significant reduction of the production, use and impact of hazardous chemicals and the full phase-out of the most harmful chemicals."
• To ensure a global level playing field, the EU should have the explicit power to regulate the import of products made with process chemicals banned in the EU and ban the manufacture for export of chemicals banned for use within the EU.
• REACH processes currently favor industry incumbents and ignore the economic benefits for companies investing in safe alternatives. The document suggests identifying market leaders through surveys and introducing fees for using substances of concern to create incentives for substitution.
• Enforcement of REACH is deficient due to a lack of resources in Member States and capacity at ECHA. Proposed improvements include giving ECHA the power to withdraw registration numbers and introducing civil liability for violations of health-protecting risk management measures.
• Transparency should be increased by making the notification of information under Articles 33 and 66 compulsory rather than voluntary, and by requiring the disclosure of parent company names and narrow tonnage bands.

APA

ClientEarth (2022). REACH 2 - Shift the trend. https://www.clientearth.org/media/tnjiam3r/2204-clientearth_reach_reform_4_demands.pdf

Chicago

ClientEarth. REACH 2 - Shift the trend. 2022. https://www.clientearth.org/media/tnjiam3r/2204-clientearth_reach_reform_4_demands.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=REACH 2 - Shift the trend |date=April 2022 |url=https://www.clientearth.org/media/tnjiam3r/2204-clientearth_reach_reform_4_demands.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2022reach, author = {{ClientEarth}}, title = {{REACH 2 - Shift the trend}}, publisher = {ClientEarth}, year = {2022}, month = apr, url = {https://www.clientearth.org/media/tnjiam3r/2204-clientearth_reach_reform_4_demands.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }