Demand #2: No data no market - from slogan to reality

The document outlines specific demands for the 'REACH 2' reform to address systemic data gaps in the EU chemical market. It argues that the original 'no data, no market' principle failed because registration requirements were too vague and did not cover all substances, such as polymers and low-tonnage chemicals. ClientEarth proposes expanding registration obligations, introducing new reporting duties for downstream users, and increasing transparency for investors and consumers regarding substances of very high concern (SVHCs).

• The 'no data, no market' principle of the original REACH regulation failed to provide sufficient information because requirements did not cover all substances and were too vague for public authorities and consumers to obtain meaningful data on chemical use.
• A significant portion of the EU chemical market remains unmonitored; of approximately 100,000 monomer substances on the market, the vast majority are not registered, and of the 26,000 that are registered, only about 500 are considered truly understood and tracked.
• Data gaps have severely hindered the ability of authorities to enact restrictions; between January 2011 and March 2022, only 28 restrictions were enacted, an average of 2.5 per year, which is far below the 11 yearly restrictions expected at the regulation's adoption.
• ClientEarth proposes that REACH 2 expand information requirements to include endocrine disruptive chemicals (EDCs), neurotoxicity, immunotoxicity, and polymers, and introduce mixture assessment factors to account for simultaneous exposure to multiple chemicals.
• The document recommends new obligations for downstream users to report the use of substances from the Candidate List or those on the Registry of Intention to the European Chemicals Agency (ECHA) early in the regulatory process.
• Transparency for investors and civil society is currently limited by ECHA's reluctance to publish specific data; the document calls for the mandatory disclosure of tonnage per registrant, the names of parent companies, and information on the companies behind 'Only Representatives'.
• The 'right to know' for consumers regarding substances of very high concern (SVHCs) in articles is described as having degenerated into a 'right to ask' because suppliers often fail to respond to requests.

APA

Schenten, J. (2023). Demand #2: No data no market - from slogan to reality. ClientEarth. https://www.clientearth.org/media/qazbblfs/ce_reach-reform_demand-2_nodata_nomarket_made_real.pdf

Chicago

Schenten, Julian. Demand #2: No data no market - from slogan to reality. ClientEarth, 2023. https://www.clientearth.org/media/qazbblfs/ce_reach-reform_demand-2_nodata_nomarket_made_real.pdf.

Wikipedia

{{cite press release |last1=Schenten |first1=Julian |title=Demand #2: No data no market - from slogan to reality |publisher=ClientEarth |date=March 2023 |url=https://www.clientearth.org/media/qazbblfs/ce_reach-reform_demand-2_nodata_nomarket_made_real.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{schenten2023demand, author = {Schenten, Julian}, title = {{Demand \#2: No data no market - from slogan to reality}}, publisher = {ClientEarth}, year = {2023}, month = mar, url = {https://www.clientearth.org/media/qazbblfs/ce_reach-reform_demand-2_nodata_nomarket_made_real.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }