Eurospace calls on the European Commission to reflect special features and essential role of space products in the planned revision of the REACH Regulation

1 June 2021 – Today, Eurospace has submitted its response to the European Commission’s (EC) call for feedback on its Inception Impact Assessment (“IIA”) of 4 May 2021 titled “Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals”.  This initiative – also known as REACH Revision Roadmap – was launched under the EC’s Chemicals Strategy for Sustainability (CSS) published on 14 October 2020, and is expected to result in an EC proposal to be adopted by the end of 2022 (see EC REACH Revision website).

In its detailed feedback paper (available here), Eurospace notes that the list of envisaged amendments to REACH affects all its main processes, including proposals of critical interest to the European Space Sector, such as simplifying communication in the supply chains, a reform of the authorisation and restriction processes and the introduction of an “essential use” concept. While these amendments may offer some possible benefits for the sector, they also raise some serious concerns with regard to regulatory predictability, obsolescence and supply chain risks. Also, the new categories of “most harmful chemicals” and “substances of concern” may contribute to an added burden for their tracking in products.

As a key demand, Eurospace recalls the specificities of the European Space Sector and societal importance for Europe, which is already reflected in a number of existing exclusions for equipment designed to be sent into space under several pieces of product-related EU legislation, and the need for coherence with these in the REACH Regulation. Other key demands include regulatory simplification, the need for a holistic approach to chemicals regulation supported by proper impact assessments and more predictability. Reporting on substances in articles should continue to be aligned with the REACH Candidate List and the definition of Substances of Very High Concern (SVHC).

The Eurospace feedback is the first key deliverable prepared with the support of the CSS Space Focus Group, a new 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 (see Eurospace News of 26 April 2021).

It should be noted that the present EC call for feedback and Eurospace response only mark the beginning of a longer process. A more extended public consultation by the EC on its detailed revision plans (still to be elaborated) is expected in the beginning of 2022. Following adoption of the REACH Revision proposal by the EC it will be passed to the European Parliament and the Council as the co-legislators. The adoption of a revised REACH Regulation is not expected before 2023/2024.

Contacts:

  • Group coordinator and REACH expert: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., tim.becker@reachlaw.fi; +358 (0)40 773 8143
  • Secretariat: Pierre Lionnet, Research and Managing Director, ASD-EUROSPACE, pierre.lionnet@eurospace.org, +33-(0)1 44 42 00 70