Socio-economic assessment and REACH authorisation

The report argues that the Socio-economic Assessment (SEA) tool used in REACH authorisations is flawed due to a narrow focus on quantitative cost-benefit analysis (CBA), which prioritises business-as-usual over innovation and substitution. It claims that ECHA's guidance encourages a micro-economic perspective focused on applicant companies rather than a broad societal perspective. The authors recommend abandoning the current SEA model in favour of integrating socio-economic factors into a broader analysis of alternatives and reforming the SVHC listing and authorisation process to increase the incentive for substitution.

• The current application of SEA favours a narrow interpretation of social factors, primarily driven by the preference for quantitative cost-benefit analysis (CBA), which prioritises the continued use of dangerous substances over innovation.
• There is a significant mismatch between the broad scope of socio-economic factors intended by REACH and the narrow focus encouraged by ECHA's decision-making documents, which prioritise industry impacts over broader societal considerations.
• The selection of 'business-as-usual' as the baseline for SEA focuses the assessment on losses borne by polluters rather than the societal benefits of transitioning to alternative solutions.
• ECHA's preference for monetised data and CBA leads applicants to neglect non-quantifiable impacts, such as wellbeing or the social acceptability of job losses.
• The European Commission is accused of failing its legal obligation to consider information beyond the applicant's dossier and of pressuring SEAC to provide 'pre-decisions' on proportionality.
• The SEA tool has become disproportionately resource-intensive because it is often used to justify the length of review periods or to salvage defective applications that should otherwise be rejected.
• The report proposes that the REACH reform should end the use of SEA as currently applied and instead incorporate socio-economic factors into the analysis of economic feasibility and substitution plans.

APA

Roger, A., & Duguy, H. (2021). Socio-economic assessment and REACH authorisation. ClientEarth. https://www.clientearth.org/media/wg2drrxv/socio-economic-assessment-and-reach-authorisation.pdf

Chicago

Roger, Apolline, and Hélène Duguy. Socio-economic assessment and REACH authorisation. ClientEarth, 2021. https://www.clientearth.org/media/wg2drrxv/socio-economic-assessment-and-reach-authorisation.pdf.

Wikipedia

{{cite report |last1=Roger |first1=Apolline |last2=Duguy |first2=Hélène |title=Socio-economic assessment and REACH authorisation |publisher=ClientEarth |date=October 2021 |url=https://www.clientearth.org/media/wg2drrxv/socio-economic-assessment-and-reach-authorisation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{roger2021socioeconomic, author = {Roger, Apolline and Duguy, Hélène}, title = {{Socio-economic assessment and REACH authorisation}}, institution = {ClientEarth}, year = {2021}, month = oct, url = {https://www.clientearth.org/media/wg2drrxv/socio-economic-assessment-and-reach-authorisation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }