Directions for the REACH revision – CARACAL 54

ClientEarth's response to the CARACAL-54 presentation on the REACH revision emphasizes the need to modernize registration requirements, enhance transparency, and maintain the phase-out goal for substances of very high concern (SVHCs). The organization strongly opposes making the Analysis of Risk Management Options (RMOA) mandatory, claiming it would create regulatory bottlenecks and undermine the objective of phasing out hazardous chemicals. Key recommendations include introducing a mixture assessment factor (MAF) of at least 100, expanding the scope of registration to include polymers, and harmonizing sanctions across EU Member States to ensure effective enforcement.

• ClientEarth opposes the proposal to make the Analysis of Risk Management Options (RMOA) a mandatory upfront step, arguing it would delay regulatory action, waste resources, and potentially violate the phase-out goal for substances of very high concern (SVHCs) established in Article 55 of REACH.
• The document argues that repurposing the Candidate List (CL) as a general tool for prioritizing regulatory action would weaken the 'anticipatory effect' that currently drives companies to seek substitutes for SVHCs.
• To address the risks of combined chemical exposures, ClientEarth supports the introduction of a generic mixture assessment factor (MAF) with a recommended value of at least 100.
• ClientEarth recommends strengthening the 'no data no market' principle by introducing a validation mechanism for registration dossiers, reducing the validation timeframe to 5 years, and granting ECHA the power to revoke registration numbers for persistently non-compliant dossiers.
• The organization advocates for a tiered regulatory approach to polymers, which are currently exempt from registration, starting with a notification step to identify a subset requiring full registration.
• ClientEarth calls for the harmonization of sanctions across EU Member States to replace the current 'soft approach' of written advice, suggesting the introduction of binding criteria and a public 'name and shame' database of non-compliant companies.

APA

ClientEarth (2025). Directions for the REACH revision – CARACAL 54. https://www.clientearth.org/media/u4kjfqjs/caracal-54_clientearth-comments_reach_rev.pdf

Chicago

ClientEarth. Directions for the REACH revision – CARACAL 54. 2025. https://www.clientearth.org/media/u4kjfqjs/caracal-54_clientearth-comments_reach_rev.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Directions for the REACH revision – CARACAL 54 |date=April 2025 |url=https://www.clientearth.org/media/u4kjfqjs/caracal-54_clientearth-comments_reach_rev.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2025directions, author = {{ClientEarth}}, title = {{Directions for the REACH revision – CARACAL 54}}, publisher = {ClientEarth}, year = {2025}, month = apr, url = {https://www.clientearth.org/media/u4kjfqjs/caracal-54_clientearth-comments_reach_rev.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }