Chemicals are an integral part of our society. They play an important role in the economy. In order to know, manage and, where necessary, limit the risks of chemical substances, it is crucial to efficiently implement European legislation and regulations.
The REACH & CLP regulations together form the core of the European hazardous substances’ legislation. It is our conviction that an efficient implementation of the REACH & CLP obligations in a sustainable chemical management approach of companies makes a crucial contribution to the safe use of chemical products for people and the environment in the supply chain and on the workplace.
It is very important that the implementation of REACH & CLP goes in a logical connection with the implementation of obligations from other European product-specific legislation such as biocides, cosmetics, etc., the Occupational Safety and Health and Environmental legislation and related national legislation.
From the common interest of being able to use chemical products safely for people and the environment, we see a combined effort by the following parties:
- Producers, Importers and Downstream Users who make mixtures are the parties that place chemical products (substances and mixtures) on the European market. From this role, it is their primary responsibility to ensure reliable product identification, clear product composition and substantiated hazard classification and labelling of the products. This product information is passed on in the supply chain via sound safety data sheets (SDS) in accordance with REACH & CLP.
- Manufacturers and Importers, also known as registrants under REACH, are jointly responsible for the management of complete REACH registration dossiers with reliable substance information and well-founded limit values. In our opinion, it is up to the registrants to actively anticipate any new or different insights into substance risks and / or different limit values within the EU by keeping the registration dossier up-to-date and accurate.
- Downstream users, including distributors, who place chemical products on the European market on their own or in their product (mixture or article) are primarily responsible for the complete passing on of the correct product information, REACH compliance data and relevant safe use information in a sound safety data sheet in accordance with REACH & CLP.
- Downstream users, including end users, who use chemical products should use the chemical products safely according to the safety data sheet of the supplier. Any uncertainties or problems with the safe use must be resolved as much as possible in dialogue with the suppliers. Only in this way can both parties actively ensure safe use in the supply chain.
- European and national policy makers are primarily responsible for an unambiguous and consistent approach to hazardous substances within the EU and its Member States. The focus should be on efficient, effective and non-overlapping legislation for chemical products applicable in all EU countries.
It would be good to work as far as possible on the basis of European frameworks with as few divergent national obligations as possible. It would also be good if policymakers had more knowledge of companies' chemical management approaches. More dialogue between policymakers and companies on how policy wishes fit into the chemical management approach of companies could lead to companies drawing up a more sustainable chemical management approach.
- National enforcement is primarily responsible for ensuring that companies comply with legal obligations. It would be good if they also had an active communication role between the parties, if they notice that well-intentioned policy initiatives for the safe use of chemical products are not fit in with or possibly even undermine the chemical management approach of companies.
It is our mission to support companies and sectors to use their products safely in the supply chain and on the work floor through the efficient application of REACH and CLP in a logical connection with the Occupational Safety and Health and Environmental legislation.
We want to work with (European) companies and sectors that take their responsibilities seriously. We want to help parties to jointly arrive at practical solutions that meet legal requirements, take account of the company's interests and provide added value for the safe use of chemical products in the supply chain and on the workplace.
We would like to think along with and contribute to practical solutions where policy frameworks do not yet seem to be fully working together towards an unambiguous approach to the safe use of chemical products in Europe and in the Netherlands. We want to make the lessons learned and practical solutions as developed with companies available to the rest of the companies in Europe as much as possible.