Consultation on the regulatory fitness of chemicals legislation

Consultation on the regulatory fitness of chemicals legislation

Consultation on the regulatory fitness of chemicals legislation has now closed

Open Public Consultation - Fitness Check on the most relevant chemicals legislation (excluding REACH), as well as related aspects of legislation applied to downstream industries

The European Commission (DG Internal Market, Industry, Entrepreneurship and SMEs (DG GROW) and DG Environment) is conducting a fitness check on chemicals legislation (excluding REACH), as well as related aspects of legislation applied to downstream industries.  The fitness check of chemicals legislation is a comprehensive evaluation of the policy area, assessing the relevance, coherence, effectiveness, efficiency and added value of the legislative framework for the risk management of chemicals.  It also identifies excessive administrative burdens, overlaps, gaps, inconsistencies and/or obsolete measures.  This will promote better legislation, making it more responsive to current and future challenges and help improve implementation.

The scope of the fitness check covers chemical and chemical-related legislation, encompassing legislation governing hazard identification and classification of chemicals and legislation governing risk management measures for chemicals.  This includes chemical-related aspects of worker safety legislation, transport legislation, environmental protection legislation, product control legislation, as well as supporting legislation.  The list of the legislation covered by the fitness check can be found under ‘Supporting Documentation’.

Please note that the REACH Regulation is not covered by this exercise as it will be the subject of a separate evaluation and a dedicated public consultation on the REACH Regulation will be organised later this year.

The European Commission (DG GROW) has commissioned a team led by Risk & Policy Analysts Ltd. (RPA) to undertake a study to support the Commission to the preparation of this fitness check (the terms of reference are available online at -  The current open online public consultation is part of the stakeholder consultation and its results will be analysed by RPA and the study team.  Please note that the results may also be used in the context of other studies in the chemicals field.  The objective of the public consultation is to obtain stakeholder views on the functioning of the legislative framework for chemicals.  The responses will be taken into consideration in the preparation of the Commission Staff Working Document, presenting the results of the fitness check.

For more details on the fitness check itself, please see the following resources:

For more details on the REFIT Programme and public consultations, please see the following resources:

This consultation will last for 12 weeks.  Responses must be submitted by Friday 27th May 2016.

Open Public Consultation Questionnaire

The questionnaire is available in English, German and French and has five parts:

  • Part I – General Information about respondents:  The first part contains questions about the respondents.
  • Part II - General Questions:  The second part contains general questions for respondents interested in chemicals legislation, but who may not be familiar enough with the existing legislative framework to answer more detailed questions.
  • Part III – Specific Questions:  The third part contains specific questions which require more extensive knowledge and/or experience of the chemicals and chemicals-related legislation.
  • Part IV – Specific Questions on the CLP Regulation:  The fourth part contains specific questions on the CLP Regulation.
  • Part V - Additional Comments: The fifth part enables you to provide additional comments on the overall EU legislative framework for chemicals in order to feed into the Fitness Check.

All questions in the first two parts are compulsory.  You may choose to skip the specific questions in Parts III and IV.  Part V is also optional.  In addition, for all questions it is possible to answer 'no opinion' or 'I don't know'.

You may interrupt your session at any time and continue answering at a later stage.  Once you have submitted your answers online, you will have the option to download a copy of the completed questionnaire for your own records.

Electronic versions of the public consultation questionnaire can be found at the following links.  To facilitate the preparation of your contribution, pdf versions of the questionnaire are also available under ‘Supporting Documentation’:

  • Click here to complete the English version of the public consultation questionnaire
  • Click here to complete the French version of the public consultation questionnaire
  • Click here to complete the German version of the public consultation questionnaire

Privacy Statement:  The collected personal data and all information related to the above-mentioned public consultation is stored on a computer of the external contractor, acting as processor, who must guarantee data protection and confidentiality as required by Regulation (EC) 45/2001.  Please see the full Privacy Statement for further detail, which can be accessed under ‘Supporting Documentation’. 

The data provided by all respondents will be aggregated and anonymised, and all information provided by any individual company/entity will be kept confidential.  If you have specific concerns about how your data will be treated or questions about the study more generally, please contact Carl Clarke ( to discuss your concerns.

Targeted Data Collection

In addition to the open public consultation questionnaire, a more targeted data collection exercise has been undertaken to obtain additional input to the fitness check.  Further information on the targeted consultation can be found here.

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