Advancing REACH: Substitution principle (WP 10) (FKZ: 3717 67 410 0)

Substitution is the replacement of hazardous substances by less hazardous alternatives. The intended high level of protection for human health and the environment, should be achieved under REACH, amongst others by triggering and promoting substitution. Not only the authorisation and restrictions procedure act in this regard, but also other REACH elements support substitution, such as the high quality data on substance properties and their uses from registration and substance evaluations.

Alternatives are necessary that present better and safer solutions for problematic uses of hazardous substances and which are economically and technically feasible. For this, alternatives are sought that ensure the desired technical functionality but without being structurally similar and hence potentially equally hazardous.

In this sub-study of the project “Advancing REACH” the impacts of REACH on the substitution of hazardous chemicals are analysed by means of a literature analysis and assessment of case studies. Based on these assessments, recommendations are derived how REACH could support functional substitution even better than up to now. The recommendations range from possibilities to more efficiently design the REACH processes up to a national monitoring of production and use of selected problematic substances. Some recommendation could be directly implemented, while others would require implementation in a mid-term perspective.

Dirk Jepsen

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