Stakeholder views on hot topics in chemicals safety

1. Helsinki Chemicals Forum 2017
Stakeholder views on hot topics in chemicals safety
Welcome to this report on the debates held at the ninth
annual Helsinki Chemicals Forum. This year’s event
attracted 189 delegates from 39 countries. The 2017
Forum discussion on five key themes ranged from the
role chemicals safety plays in the UN’s sustainable
development goals (SDGs) to how substances of very
high concern (SVHCs) are managed in products in
a free trade world. The Helsinki think tank addressed
the changing global political landscape, as well as
the increasing challenges we face protecting the
environment and human health, while putting forward
the case for the safe management of chemicals.
With a number of significant anniversaries, most
notably it being ten years since the EU’s REACH
Regulation entered into force, the two-day forum
kicked off by looking at what chemicals legislation
has achieved over the last decade. Following this
reflective theme, topics moved to the future, asking
what the business case is for the UN’s SDGs that were
adopted in 2015. Further panels covered the post-
2020 global chemicals supply chain, asking what will
be the drivers for market supply and demand and will
chemicals product safety emerge a winner or loser.
It also addressed the need to speed up chemicals
assessments and closed on the theme of SVHCs
in products and whose job is it to control these
in a free trade world?
This report is prepared by independent news service
Chemical Watch and aims to be a balanced and
accessible reflection of two days of debate in order
to further understanding. We have not taken sides,
or judged comments on their accuracy, veracity
or fairness.
This is not a formal report because this annual forum
is not an official session and its conclusions do not
represent a consensus. Instead, this report offers
a reference point for policymakers, companies,
academics and others – presenting the voice of the
people in the room at this key annual gathering about
the important topics discussed. On the last pages of
the report we provide an unedited selection of virtual
comments and questions that were posted on the
forum message wall to ensure that audience views
are reflected.
Mamta Patel
CEO, Chemical Watch
Luke Buxton
Europe Editor, Chemical Watch
Leigh Stringer
Global Business Editor, Chemical Watch

2. Panel 1:
What has chemicals legislation done
for us over the last decade?
Panel 2:
The sustainable development goals –
is there a business case?
Panel 3:
Post-2020 global chemicals supply chains –
what will be the drivers for market supply and
demand and will chemicals product safety
emerge a winner or loser?
Panel 4:
Speeding up chemicals assessments – from novel
information to new management approaches,
what works?
Panel 5:
Substances of concern (SVHCs) in products –
whose job is it to control these in a free trade world?
Writing on the wall:
An unedited selection of comments posted
to the message wall by the audience
Helsinki Chemicals Forum
www.helsinkicf.eu
Chemicals Forum Association
Messuaukio 1, 00521 Helsinki,
Finland
Hannu Vornamo
Secretary general
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hannu.vornamo@elisanet.fi
Tarja Gordienko
Communications manager
+358 50 584 7262
tarja.gordienko@messukeskus.com
Ida Ågren
Project assistant
+358 40 450 3181
ida.agren@messukeskus.com
Chemical Watch contacts
Mamta Patel
CEO
+44 (0) 203 603 2110
mamta.patel@chemicalwatch.com
Leigh Stringer
Global business editor
+44 (0) 203 603 2119
leigh.stringer@chemicalwatch.com
Luke Buxton
Europe editor
+44 (0) 203 637 5793
luke.buxton@chemicalwatch.com
Helsinki Chemicals Forum contacts
Contents
ALLPHOTOS©MessukeskusHelsinki

3. Panel Debate 1:
What has chemicals legislation done for us over
the last decade?
Chemicals legislation
Key issues
• Some REACH registration dossiers are inadequate
in terms of poor or insufficient data
• Even so, more information is now far more accessible.
The question is how will the wealth of information
be used?
• Improvements to REACH are needed – it is too slow,
too scientific and too detailed
• In particular, REACH authorisation and restriction
processes are not perfect and need improving –
debate continues around which regulatory measure
should be used for certain substances/circumstances
• Regulatory and industry efforts on ‘emerging’ issues,
such as nanomaterials and endocrine disrupting
chemicals, need to speed up
• A better interface is needed between REACH and other
EU legislation, such as that dealing with occupational
health and waste
• More substances need to be added to the authorisation
list – they currently average about three per year
• NGOs and authorities say REACH can stimulate
competition and innovation, while some industry
players say this is not necessarily the case
• While there are now comparable REACH enforcement
projects in different member states, the level
of enforcement is still an important issue
• Questions remain on how to achieve and manage
an effective circular economy when some products
contain hazardous substances
• Global mutual acceptance of data remains a major
challenge and this reluctance is a barrier to faster
regulatory action on hazardous chemicals
Achievements
• Chemicals legislation, particularly REACH,
has closed the information gap on substances
• There is better communication between
industry players
• There is now better information for downstream users
What more can be done?
• Echa can learn from the experiences of regulating
authorities in countries like Canada and vice versa
• Current processes for REACH restriction and
authorisation need to be improved
• Regulators need to be braver and take more
risks to achieve clearer outcomes more quickly
• Regulations need to be more pragmatic
Mood in the room – key take-home messages
• There is a need for more efficient processes
• REACH is not perfect but it is working
• How the information gathered through REACH
is used will measure the Regulation’s success
• There is no alternative to REACH – stakeholders
are encouraged to roll up their sleeves and make
it more efficient
Panellists
Moderator: Erwin Annys (Cefic)
Panel: Vito Buonsante (ClientEarth); Björn Hansen (DG Environment, European Commission); Andrea Paetz (Bayer);
Jake Sanderson (Environment Canada); Jan Wijmenga (Ministry of Infrastructure and Environment, the Netherlands).
Context
The tenth anniversary of the entry into force of the EU REACH Regulation gives industry stakeholders the opportunity
to review its track record. Panellists and delegates discussed what this and other chemicals legislation has done to protect
human health and the environment, and if it has managed to protect competitiveness and support innovation at the
same time.
The debate

4. Panel Debate 2:
The sustainable development goals –
is there a business case?
SDGs
Current status
• Chemicals safety permeates all 17 SDGs
• The SDGs can only be achieved if chemicals
are managed safely
• Much progress has been achieved on the way to the
Saicm 2020 goals, and the SDGs present a further
opportunity to develop a more comprehensive global
chemicals management framework post-2020
• Because chemistry runs through all SDGs, we need
a multi-sectoral approach to chemicals safety
The business case
• Industry will contribute to the SDG goals and
Saicm processes today and in the future
• Incentives are needed to encourage innovation
from industry
• SDGs present a large opportunity for innovative
SMEs to develop alternative chemicals, materials
and technologies
• To fulfil any of the 17 SDGs, emphasis should be put
on number five – achieve gender equality and empower
all women and girls. Women and chemicals safety play
an important role in achieving this
• Over the last two decades, the European chemicals
industry has lost worldwide market share, while
the global market has increased rapidly. Topical
sustainability issues, like the transition to a low
carbon economy or the promotion of adoption towards
circular economy principles, offer new opportunities.
In this respect, the SDGs give companies an additional
roadmap for innovating products to meet societal
challenges in future
Mood in the room – key take-home messages
• All SDGs rely, in some way, on the safe management
of chemicals
• Industry and the public need to be aware that the
SDGs represent opportunities as well as challenges
• Chemicals safety is an important piece of the
sustainability puzzle and every step of the challenge
must be considered, avoiding thinking in silos
• To achieve chemicals safety and the SDGs, stakeholders
must come together to develop innovative solutions
to the challenges we face
Panellists
Moderator: Achim Halpaap (Chemicals and Waste Branch, Unep, Belgium)
Panel: Ricardo Barra (University of Concepción, Chile); Leticia Carvalho (Ministry of Environment, Brazil);
Qian Cheng (Greenpeace East Asia, China); Timo Unger (Hyundai Europe, Germany); Hartwig Wendt (Cefic).
Context
Safe chemicals management plays an important role in achieving several of the UN’s sustainable development goals
(SDGs), which were adopted in 2015 to guide societal and planetary needs up to 2030. Panellists discussed how
businesses should engage with them and explored the bottom-line risks of not doing so.
The debate

5. Panel Debate 3:
Post-2020 global chemicals supply chains –
what will be the drivers for market supply and demand and
will chemicals product safety emerge a winner or loser?
Supply chain challenges
• Sustainable products and energy demands will be
strong market drivers post-2020 – the latter are putting
great pressure on chemicals producers, as well as
article manufacturers
• As the manufacturing of nanomaterials increases,
chemicals safety will have to be addressed at the
nanoscale much faster than it is currently
• Consumers are becoming increasingly educated on
chemicals and are demanding safer, greener products
• Alignment of global frameworks is needed to help
businesses obtain the right information they need
• The circular economy will require a complete
transformation of business models
• Political, economic and social uncertainty are potential
barriers to transforming business models
• There are multiple sources of disruption affecting global
markets and business planning. This brings many
opportunities, but how can we facilitate innovation
and human progress?
Solutions
• Potential for supply chain synergies – downstream
users must work closer with chemicals producers
to develop substances that suit specific applications
• Technology, such as artificial intelligence and ‘big data’,
are potential solutions to many supply chain issues
• Regulatory harmonisation is needed in this climate
of uncertainty – setting common standards and the
reliability of chemicals are vital
• To know all chemicals in products, information
from all stages of the supply chain is required
• Personnel at manufacturing sites need to be
educated on how to obtain information on chemicals
from producers
• Restricted substances lists (RSLs) and manufacturing
restricted substances lists (MRSLs) are being used
as communication tools by downstream users
• The UN’s Chemicals in Products programme has
the potential to be an effective and useful initiative
for downstream users of chemicals
• SDGs can keep supply chains and business models
focused on the goals set
• Green chemistry has the potential to grow rapidly
and outpace conventional chemicals manufacturing
• A safer chemicals strategy for industry is crucial –
this would establish how we find and develop safer
chemicals and implement them
Mood in the room – key take-home messages
• Information is a key driver for safety
• The EU market will only become smaller
on the global stage
• Supply chains will become more complex,
along with products and the chemicals used
• The public will demand safer chemicals and industries
closest to the consumers will find it easier to change
their business models
Panellists
Moderator: Bjørn Hansen (European Commission)
Panel: Rafael Cayuela (Dow, US); Joseph DiGangi (Ipen, US); Anouschka Jansen (Foreign Trade Association, Belgium);
Mihai Scumpieru (Mitsubishi Electric Europe and Japan Business Council in Europe); Peter Smith (Cefic).
Context
Taking into account macro-economic forecasts, global market trends and supply chain needs, the panel debated what the
products of tomorrow will look like and discussed the implications for the drive to achieve safer chemicals in products.
The debate

6. Panel Debate 4:
Speeding up chemicals assessments – from novel
information to new management approaches –
what works?
Chemical assessments
Current status
• For OECD countries the mutual acceptance of data
(MAD) system is important. MAD has to evolve to
accept novel approaches to testing
• Gaining access to in vivo data is critical for regulators
to assess its value
• Development of adverse outcome pathways
and building of chemical pathways is slow
• Regulators and industry want methods that are relevant,
reproducible, broadly available, recognised as usable
for defined regulatory purposes and well characterised
• There is a fragmented global picture when it comes
to acceptance of alternative assessment by regulators
• REACH is geared towards assessing one substance
at a time, which results in slow progress in controlling
chemicals risks
• Consideration should be given to a grouping approach
to achieve faster results and reduce animal testing
• Future discussion should look at moving REACH from
being a chemicals-based regulation to a use-based one
• Companies are making use of existing data in screening
chemicals during R&D; regulators could learn from
their methodology
• Hazards of chemicals are international –
irrespective of the country in which they are used
• International hazard data should be used for local
risk assessment
• Obstacles to data sharing are more political
than technical
• People are increasingly accepting in silico and
in vitro methods for regulation requirements
• There are philosophical and social challenges to
new approaches but also to traditional in vivo testing.
We need a transparent discussion of these
• Acceptance of new approaches does not necessarily
speed up regulatory approval processes as regulators
need to check assumptions more carefully
Solutions
• Novel approaches should not be systematically
opposed in favour of traditional ones
• Stakeholders must build a strategy of how
novel approaches can fit together
• Collaboration between OECD countries is important
but it must also take place with countries outside
the OECD, such as China
• People can reach different conclusions but it must
be clear why these are reached
Mood in the room – key take-home messages
• Moving together is more important than moving faster
• There is ‘no one size fits all’ approach to chemicals
assessment
• Data should be shared and people must be transparent
about the data that decisions are based on
Panellists
Moderator: Mamta Patel (Chemical Watch)
Panel: Dorte Bjerregaard Lerche (Ministry of Environment and Food, Denmark); Anne Gourmelon (OECD);
Erika Kunz (Clariant); Brian Richards (Office of Chemical Safety, Australia); Russell Thomas (US EPA).
Context
Stakeholders in various countries are trying different approaches to avoid animal testing. The aim is to speed up chemicals
assessment and management including grouping, fast-tracking restrictions and computational screening. But how does
this all work in practice and what are the trade-offs for society in using these approaches?
The debate

7. Panel Debate 5:
Substances of concern (SVHCs) in products –
whose job is it to control these in a free trade world?
Key issues
• There is a lack of knowledge about the presence
and fate of hazardous substances in articles
• Analysing all chemicals in products on the EU market
is not a viable solution as millions of products are
imported. It would be too costly
• Legislation is a baseline expectation but retailers
must have their own initiatives, such as chemicals
management programmes – which include monitoring
of suppliers – to identify sustainable practices
• Performance demands and design criteria for
certain consumer products pose real challenges.
Sometimes safer alternatives do not offer similar
performance attributes
• Transparency and communication are difficult
in complex supply chains, the actors in which
can often change
• Industry has a key role in controlling SVHCs in articles
but everybody in the value chain – governments,
manufacturers, suppliers, retailers and consumers –
has a responsibility
• Lack of comprehensive legislation in emerging
economies, such as India, is problematic for chemicals
control and consumers are less aware of the hazards
in these regions
• Substances in articles will play a prominent role
in the EU’s strategy for a non-toxic environment
• MRSLs and RSLs play an important part in combating
the problem
• Confidential business information (CBI) and intellectual
property (IP) rights can prevent open dialogue
Recommendations
• The issue can only be tackled by a combined
effort from all players in the value chain
• Action is needed nationally as well as internationally –
players should strive for harmonisation
• More transparency and better communication
will improve the handling of SVHCs in articles
• Greater consumer awareness is needed, especially
in emerging economies
• Authorities must address the interface between
waste legislation and the circular economy
• SVHCs should be tracked in order to achieve
a successful circular economy
• Third parties can potentially play a role in overcoming
issues of CBI and IP and help bring assurance and trust
Mood in the room – key take-home messages
• International collaboration is essential and everyone
in the value chain bears responsibility
• Control of SVHCs in articles is a vital consideration
in non-toxic environment strategies
• Consumer awareness of such substances must
be improved
Panellists
Moderator: Jack de Bruijn (Echa)
Panel: Ravi Agarwal (Toxics Link, India); Karin Kilian (European Commission); Remi Lefevre (Echa);
Kevin Mulvaney (American Chemistry Council); Matthias Schmid (Adidas).
Context
Unregulated EU imports of articles, which expose people and the environment to dangerous chemicals,
continue to frustrate regulators and industry. An international cross-body panel discussed the magnitude
of the challenge and what regulators and businesses can do to level the playing field.
The debate

8. »» What about enforcement?
It remains the weakest link
of a successful chemicals
management system... lack of
harmonized rules in and outside
EU discourages pro activity
of industry... when will we have
a global commitment from the
competent authorities directly
(not at the political level)?
»» Indeed enforcement by the
member states is not really
discussed even by the Dutch
representative although we
all know that it is a major flaw.
Could Bjorn and Jan explain
what will be done?
»» EEB said at ECHA's 10th
anniversary day yesterday that
there seems to be little difference
in consequences for companies
that comply by providing adequate
data to demonstrate good control
of risk vs. those that do not.
Both get a registration number.
How can this be addressed
in the next ten years?
»» #integrated and #sustainable
#chemicals and #product
policies are #prerequisites
for #circulareconomy
#ChemicalsForum @yministerio
https://t.co/ZLwVOtBhyc
»» The USA and Canada go for a
risk-based approach, whereby
the EU is following a hazard-based
approach "hunting" for SVHCs.
Can you clarify which approach (1)
serves the goals more effectively
and (2) is economically (time and
cost) more efficient?
»» What has legislation done for us?
- can the panel discuss the impact
of modernised regulation on
innovation and substitution
of hazardous chemicals?
»» What has legislation done for us?
- can the panelists each say what
would be their key performance
indicator of success (or failure)
of chemicals management in
the next 10 years?
»» 10 years has passed and more
than 80% of chemical industry
produce hazardous products.
No on the ground actions
been implemented more
than documentation!
»» Jan Wijmenga, Dutch environment
ministry: REACH a success, but
needs improving, e.g. need to
assess combination exposure
#ChemicalsForum
»» For B.H.: are sustainable/ green
chemistry going to be really
effective for circular economy
of chemicals?
»» Echa's Geert Dancet reiterates
‘consumers not getting enough
information on chemicals in
products’ #ChemicalsForum
»» Andrea Paetz of Bayer says
REACH not perfect but knowledge
and regulation of chemicals is
much better #ChemicalsForum
»» Knowing what we know now with
10 years of experience, would
REACH or its implementation look
any different if today was Day 1?
Panel 1: What has chemicals legislation done for us?
Panel 2: The sustainable development goals – is there a business case?
»» Regarding substitution, innovation,
circular economy, etc.: Could the
panel discuss how OEMs shall
address these issues. Planning
horizon and product life cycle
for e. g. TV industry may be 5 - 10
years, for the automotive industry
probably 20 - 30+ years. What
do you suggest these industries
should do when planning new
products NOW in order not to
be confronted with future SVHCs
in their products?
»» Ricardo Barra of Chile's University
on Conception says innovation
to tackle pollution eg. plastic waste
at source rather than at the end
of product life is critical especially
with the growth in middle class
consumer markets globally.
How to create the right economic
incentives to drive businesses
in this direction?
»» The SDGs are forging connections
'at organisational level' between
health, housing and environment
policy-makers in Brazil in pursuit of
sustainability eg. to end use
of lead paints. Is this happening
in other public and private sector
organisations too?
»» Greenpeace China: companies
manufacture without regard for
chemicals contamination of local
public sites and little enforcement.
What will it take to build the
impacts on health, environment,
food, water into the business
case for regulatory and business
activity?
The Writing on the Wall
An unedited selection of comments posted to the message wall by the audience

9. »» Most of the sound management
of chemicals programs/ plans
are under the SDG12 (SCP).
Considering the importance
of pesticide/ chemicals/ biocides
isn’t it better to define another
separate SDG (eg., no 18)
for chemicals pollution?
»» This morning the picture was
painted that REACH had not
impacted on the chemical
industry in Europe. Yet the CEFIC
presentation said that we had
consistently lost share from 32%
to 17%. Does this not mean that
we have effectively just exported
all our hazardous chemicals and
then purchase the finished articles
leaving the problem in the third
world. So has it really been such
a success?
»» Ricardo Barra: "Plastics is for
chemicals what carbon is for
climate change" #ChemicalsForum
good analogy on the problem
with plastics
»» European chemical industry may
have lost some of its global market
share but the overall market has
expanded massively. Instead of
lamenting the pollution elsewhere,
isn't this an opportunity for
European industry to compete
on sustainability standards of
products? REACH is raising the
product stewardship bar in Europe
and those who want to export
to the world's largest economic
bloc need to pay to play.
»» For sustainability to truly flourish,
in addition to a real global
knowledge sharing (both data and
regulations), regulations should
also be based on sustainability
pillars. Hazard alone triggers
regrettable substitution decisions
hampering sustainability overall.
The current classification system
does not allow distinguishing
substances from a potency
viewpoint. All CMRs are grouped
and stigmatized no matter
the inter-substance variability
of the potency and severity of
effects, or their environmental
production and consumption
footprint. Sustainability needs
a refined classification system
to consider more than just hazard
and grow closer to a functional
risk assessment.
»» Looking further ahead after
2020 in terms of global chemical
management as well as in line
with the underpinning principles
in Responsible Care; how does
industry justify the continuation
of manufacturing hazardous
chemicals, banned from use
in e.g. the EU, only to export to
developing countries? Are global
bans of chemicals a necessity
beyond 2020?
Panel 3: Post-2020 global chemicals supply chains
»» To Mihai Scumpieru: Is there scope
to develop ChemSherpa as a
global chemicals declaration tool?
»» Circular economy ==> rethink of
product functionality and business
models ==> increasing complexity
of supply chain communication
but also driver of up- and
downstream collaboration?
»» To Rafael Cayuela: in the race to
'singularity' where sustainability,
digital and citizen revolutions
come together, which types of
companies will be the winners
and losers?
»» When hazard reduction has
been implemented and risk
management yields proper
protection of human health and
environment, little recognition is
given and pressure/stigmatization
continues. Keeping pressure is
healthy but stigmatization and
misinformation are counter-
productive. Many hazardous
substances are key to society and
can be used safely from cradle
to grave. If more information of
presence and impact of hazardous
substances is what public wants,
let’s define a fit-for-purpose
communication tool, somewhere
between current labels and
product information sheets,
destined to reassure citizens.
»» Joe DiGangi from @ToxicsFree
shows the real cost of
chemicals and the harm from
using hazardous chemicals.
#ChemicalsForum inspiring!
»» Accuracy of hazard based
assessment is about the
same as that of tossing a coin.
Lots of wrong positives and
wrong negatives.
»» The market supply and demand
will not survive on the basis of
non-hazardous chemicals only!
Risk assessment is the key to
inform sustainable and realistic
market supply and demand.

10. Panel 4: Speeding up chemicals assessments
»» Many countries are reluctant to
accept read-across but wouldn’t
this avoid duplication and
encourage data-sharing globally?
Why are these countries saying
no to read-across?
»» Erika Kunz. @clariant nos explica
las ventajas de la herramienta
AMBIT de @Cefic LRI
en #chemicalsforum
https://t.co/H7nrtTNKSa
#pruebalo
»» A new substance is added to the
CAS register every second. If it
takes years to globally regulate
a single substance, Minamata
Convention for example - what’s
our best hope for tackling the
increasing number of substances
entering the market that potentially
increase the toxicity of our society?
Seems we are trying to reach
the top of a mountain that never
stops rising.
»» Our Danish panelist makes an
interesting point - shouldn’t we be
assessing substances on a use or
product basis? Something which
the European Commission seems
to be considering.
»» With all we hear on the variability
of results in in vivo data and on
how little animal data can predict
with certainty human reality (and
inform human safety thereby),
why do we continue to push so
much for animal testing rather
than investing more actively
in human population health
surveillance and monitoring?
Stop extrapolating with excessive
assessment factors on a very
conservative basis when the
animal models we start from seem
to be not representative or over
sensitive already! At the pace we
go any and all substance will end
up being classified and banned
with no true added value for
human safety…
»» Health surveillance can be done
in a tailored manner taking due
consideration of all relevant
parameters and using the latest
statistical analytical approaches...
it would not be more complicated
(and less fit for purpose) than
what we currently are doing
when “extrapoguessing” political
decisions based on models and
data known to be unfit to predict
human safety…
Panel 5: SVHCs in products
»» To Matthias Schmid of ADIDAS:
Extending chemical risk
management from supply tier one
back to tiers 2,3,4 must become
less and less accurate - how
confident are you that you know
what is going on?
»» India is the largest producer of
DDT (DDT use is coming back
again for malaria..etc.) and on
the other hand India itself is the
biggest victim of the chemical
industry.
»» To Ravi Agarwal: Can you foresee
a tipping point to drive mainstream
consumer awareness of product
safety, regulation and industry
proaction in India? What will
it take?
»» Hazardous chemicals in products
@EU_ECHA explains how industry
is not complying with REACH
- refusing to take responsibility
#chemicalsforum
»» Supply chain and consumer
communication and information
is a two-way process. Lack or
differences in awareness and
knowledge at each end of the
chain can only be tackled by
a common notification system
and a proper enforcement.
»» As a manufacturer I am
constantly bombarded with
compliance requests - RoHS,
REACH compliance, Palm
Oil, SVHC, FDA food contact,
Drinking Water ...... this takes
considerable time to understand,
assess and reply….I wonder if
my competitors outside Europe
just send the signed statement
back to the customer without
even reading or understanding
it or offer 5% discount to get the
business. Regulation with strong
enforcement of suppliers outside
Europe is VITAL.
»» How to address the thin line
between IPR and “must have
information” in notification
obligations?
»» @Malik_CoE @EU_ECHA
Responsibility means knowing
what is in your product and
being transparent about it.
And complying with the law
#chemicalsforum
»» Companies are populated by
citizens who like to think that
they know what a typical citizen
would want to know on the articles
they use. This guides part of
the communication standards
they develop. More partnerships
across industry sectors and with
authorities and NGOs could
deliver a more holistic view of what
citizens need to know. If there is no
agreement on what citizens need
to know, no notification system
can be built.
»» How is release (leaching and
migration) of a substance from
an article taken into account in
REACH processes or is it only
the presence of the substance
in an article that matters? Is there
a need for a notification of SVHC
substance to ECHA if exposure
to a substance in an article can
be excluded?