13 April 2022 – Today, Eurospace has submitted its feedback to the European Commission’s milestone open public consultation on the planned revision of the EU REACH Regulation on chemicals. The REACH revision is being undertaken by the Commission under its Chemicals Strategy for Sustainability (CSS) of 14 October 2020, and is still expected to result in a Commission proposal to be adopted by the end of 2022 (see EC REACH Revision website).
The Eurospace contribution consists of a response to the comprehensive Commission survey and a related Position Paper. It concludes that a revised REACH can fulfill the CSS objectives from the European Space Sector’s perspective if
- it delivers on the ambitions of burden reduction, simplification and legal certainty, especially in the framework of the authorisation and restriction reform;
- defines clear Essential Use Criteria, recognising that uses of chemicals without viable alternatives for the manufacturing of Space products in EU are likely to be essential;
- clearer signals and more long-term planning security to companies are given for the management of most harmful chemicals / Substances of Very High Concern (SVHC);
- any new duties for downstream users in relation to these substances (e.g. reporting to ECHA) are manageable, proportionate and fit for purpose;
- obsolescence risks for materials and processes in the space industry are minimised, especially from broad-scope regulatory actions.
While a number of changes are being anticipated as result of the CSS REACH revision, Eurospace stresses the need to maintain the overall stability of the REACH regulatory system as far as possible, and to avoid excessive regulatory constraints. Already today, a worrying proportion of more than 25% of all space-relevant materials marked as active in the European Space Agency (ESA) REACH Tool are impacted by the REACH Candidate List of SVHCs.
The present contribution has been prepared with the support of the CSS Space Focus Group (SFG), a splinter group of the Materials and Processes Technology Board of the European Space Components Coordination (ESCC MPTB), which is a partnership between the European Space Agency (ESA), national space agencies, and space industry represented by ASD-Eurospace. The European Defence Agency (EDA) is attending as an observer.
The contribution follows on the Eurospace (SFG) feedback to the REACH Revision Roadmap of 1 June 2021. It complements the contribution to the same consultation submitted or still expected by the AeroSpace and Defence Industries Association of Europe (ASD), as well as a number of more specific ASD contributions – supported by the SFG – to targeted stakeholder consultations by or on behalf of the Commission on certain elements of the planned REACH revision.
The Commission is planning to conclude its impact assessment for the REACH revision already by summer 2022, and still would like to pass on its formal REACH revision proposal to the European Parliament and the Council as the co-legislators by the end of 2022. The entry into force of a revised REACH Regulation is currently not expected before 2025-2027.
Consult the Eurospace (SFG) contribution of 13 April 2022 to the REACH revision:
Related previous news alerts:
- Info about the creation of the CSS Space Focus Group of 26 April 2021
- Eurospace (SFG) feedback of 1 June 2021 to the Commission’s REACH Revision Roadmap
Contacts for further information:
- SFG coordinator and REACH expert: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., email@example.com; +358 (0)40 773 8143
- Secretariat: Pierre Lionnet, Research and Managing Director, ASD-EUROSPACE, firstname.lastname@example.org, +33-(0)1 44 42 00 70