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ECHA’s Enforcement Forum Starts to Publish its Advice on Enforceability of REACH Restrictions

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On September 13, 2023, the European Chemicals Agency's (ECHA) Enforcement Forum decided to make its advice on the enforceability of REACH restriction proposals public. It officially published its first advice on the proposal to restrict creosote and related substances in treated wood. The complete REACH restriction list can be searched here.


In October 2022, the French Agency for Food, Environmental and Occupational Health and Safety (ANSES) submitted the Annex XV report to the Forum concerning the proposal for eight chemicals involving creosote. This restriction proposal aims to reduce risks of public health and environmental hazards arising from reuse or secondary use of these substances. This proposal intends to add a new entry in Annex XVII below:


The advice of ECHA’s Enforcement Forum:

1. The following definitions might require further explanation: “reuse”, “secondary use”, “treated” or “second-hand market”. A more precise definition may avoid loopholes and different interpretations by duty-holders and enforcement authorities.

2. A limit value for restricted substances is recommended to be set in case analysis is required to verify the compliance of the conditions of the restriction proposal. Also, an analytical method might be needed to analyze the restricted polycyclic aromatic hydrocarbons (PAHs) that could appear in the treated wood.

ECHA’s Enforcement Forum publishing its advice on the enforceability of REACH restrictions aims to enhance transparency in the legislative process, thereby facilitating better assessment and decision-making. This signifies a new milestone for ECHA.

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