We were pleased to welcome Cristina de Avila, Head of the Sustainable Chemical Unit| DG ENVI. A wide variety of topics surrounding the EU chemical regulatory framework currently in place aimed at reducing hazardous chemicals on the market were discussed, focusing on the implementation of REACH and CLP. The presentation also covered the challenges faced by these regulatory frameworks and how DG ENVI intends on tackling them.
We first heard about the goals and achievements of DG ENVI, these include greater transparency with the central objective of improving communication along the production chain. As well as improved chemical safety. REACH is key to achieving these objectives, with 14 thousand companies registered, it ensures accountability and thus allows for the free movement of chemicals inthe EU. This is apparent with its ‘no data no market’ initiative whereby industries have to provide safety information on substances. This provides EU global leaders with chemical knowledge and management. These regulations are further implemented through CLP whereby substances are classified to protect workers as well as the environment.
It is however clear that there is still room for improvement, particularly due to the fact that systems are not regularly updated, as information about exposure and usage of chemicals is vital. Moreover, the 2018 REACH Review demonstrated that one third of registration dossiers are non-compliant. Other areas for improvement include better tracking of hazardous substances in articles as well as introducing incentives to substitute these chemicals. Therefore, although REACH and CLP are integral, it is apparent that they need to be simplified in terms of risk assessment and management as a means to facilitate better implementation of policy.
The REACH Evaluation Action Plan resulted in the rectification of REACH, one of which was the Commission’s amendment of the compliance check target from 5% to 20%. This means that ECHA evaluates 20% of dossier in each tonnage band. By 2020 ECHA is set to conclude which high tonnage substances are a priority and by 2023 sets to introduce compliance checks with high tonnages. The final objective is to introduce compliance checks with lower tonnages by 2027. It is also important to note that policy makers areconfronted with the issue of essential vs non-essential PFAS on an international level. The concept of essential usage already exists and discussion around this issue needs to happen. Due to the changing nature of the world and introduction of new substances, the classification of chemical needs to be looked at with mobility.
With the emergence of new policies such as the Green Deal along with the Zero Pollution Strategy, it is evident that the importance of regulating chemicals and minimising their impact is crucial. The focus does however remain centred around the question of how to address and achieve these policies in the next decade. The framework currently in place is good, rather it is the way in which authorisation is done which needs to be reformed. For this reason, it is clear that there is no need for more legislation. For example, despite these policies, single use plastic in the EU remains prominent, for this reason registration requirement is a possibility. However, with the new commission set to take office on the 1st of November, it is still very early to say how these policies will be materialised.
Head of Unit | DG Environment, European Commission
Cristina de Avila is Head of the Sustainable Chemicals Unit of the European Commission’s Environment Directorate-General. Prior to that, she was Deputy Head of the same unit, where she led the unit's work on REACH and CLP. She has been working on EU chemicals policy since 2004, being involved in the co-decision negotiations and the implementation of the REACH Regulation since its adoption. Before joining the Commission, Cristina worked for over five years as policy analyst and lobbyist, in two public affairs consultancies in Brussels and in an NGO in Spain. Her main area of expertise was EU environment policy, in particular the sectors on waste and product policy. Prior to her specialisation in EU law and community environment policy, Cristina worked as a lawyer for over two years. Cristina studied law in the University Complutense of Madrid, has a post-graduate diploma on International Relations from the Institute of Social Studies in The Hague and an LL.M in European Business Law from the University of Amsterdam.