REACH 2.0 risk management system

ClientEarth argues that the current REACH risk management system is unable to match the volume and rate of chemicals entering the market. The document proposes simplifying restriction processes, introducing a 'high concern' trigger for action, and creating a tiered system for transition periods to ensure the significant reduction of hazardous chemicals.

• The current REACH risk management system suffers from structural weaknesses: the 'fast track' Article 68.2 process is underused, the Article 68.1 process is overly burdensome with an excessive burden of proof, and the Annex XIV authorisation system has become too resource-intensive.
• To align with the EU Chemicals Strategy, all restriction processes should share a common goal of significantly reducing the production, use, and impact of hazardous chemicals, including a full phase-out of the most harmful substances.
• The trigger for regulatory action under Article 68.1 should be changed from 'unacceptable risk' to 'high concern' to lighten the administrative burden. High concern should be automatically assumed for the most harmful substances, including CMRs, EDCs, PBT, vPvBs, PMT, and vPvM.
• The EU should establish a global level playing field by gaining the power to regulate imports of products made with process chemicals banned in the EU and banning the manufacture for export of chemicals banned within the EU.
• ClientEarth recommends that the legislator immediately adopt bans on CMRs in childcare articles and on EDC, PBT, and vPvB substances (including PMT and vPvM) in mixtures available to the general public via amendments to Annex XVII.
• To reduce reliance on industry-led calls for evidence, registration requirements should be expanded, including a new requirement for downstream users to report their use to ECHA.
• A tiered approach to transition periods is proposed based on the criticality of use: a 1-year grace period for non-essential uses, 1-3 years for critical uses with available alternatives, 3-6 years for those requiring more time, and 6-12 years for critical uses with no alternative (subject to mid-term review).

APA

Roger, A. (2022). REACH 2.0 risk management system. ClientEarth. https://www.clientearth.org/media/egqnvtmj/2204-clientearth_suggestions_upgrade_risk_management_system.pdf

Chicago

Roger, Apolline. REACH 2.0 risk management system. ClientEarth, 2022. https://www.clientearth.org/media/egqnvtmj/2204-clientearth_suggestions_upgrade_risk_management_system.pdf.

Wikipedia

{{cite press release |last1=Roger |first1=Apolline |title=REACH 2.0 risk management system |publisher=ClientEarth |date=April 2022 |url=https://www.clientearth.org/media/egqnvtmj/2204-clientearth_suggestions_upgrade_risk_management_system.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{roger2022reach, author = {Roger, Apolline}, title = {{REACH 2.0 risk management system}}, publisher = {ClientEarth}, year = {2022}, month = apr, url = {https://www.clientearth.org/media/egqnvtmj/2204-clientearth_suggestions_upgrade_risk_management_system.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }