Depending on the outcome of EU Exit negotiations, the UK may (or may not) remain in alignment with the EU system for the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).  If not, a UK equivalent system for registering chemicals will be put in place, run by the UK Health and Safety Executive (HSE). 

The UK Department for Environment Food and Rural Affairs (Defra) has commissioned a team led by RPA to assess the impacts of the UK’s exit from the European Union (‘Brexit’) on the operation of a broad range of businesses in the chemicals value chain.

We are looking for companies in the chemicals supply chain willing to take part in semi-structured interviews (of around one hour) on their expectations post-EU exit and provide information that will help Defra to assess the costs and benefits of future options for a new UK regime for chemicals.   If you/your company would like to be a part of the study, please complete the registration form at this link.

We have also launched an on-line survey which is aimed at different types of businesses including manufacturers, importers, Only Representatives, distributors, formulators and downstream chemical users in key industry sectors.  Click here to participate

Further details on the study

The overall objectives of this research are to:

• Assess the impact of the post-EU Exit chemicals regulatory regime on the operation of a broad range of businesses in the chemicals value chain; and
• Inform future strategy for implementation and communication of regulatory changes that are developed post EU Exit.

A research team led by RPA and comprising Ramboll and PTJH Consulting Ltd (PTJH) has been appointed to carry out the study.  

The research is to be carried out through the use of semi-structured interviews, focusing on one chemical product for each interviewee and company’s expectations post EU Exit.  We would also like to collect some information on compliance costs, to inform Defra’s future economic assessments. 

Interviews will be carried out from late January to the end of February 2019.  Companies participating in the interviews may also be asked to take part in follow-up interviews after EU Exit, to allow exploration of the changes that have actually taken place, their costs and benefits, and recommended actions for government to take in future. 

Defra and HSE guidance in the event of a no-deal Brexit

Guidance from Defra and the HSE can be found below:

Defra: https://www.gov.uk/government/publications/regulating-chemicals-reach-if-theres-no-brexit-deal

HSE:  http://www.hse.gov.uk/brexit/uk-reach-additional-guidance.pdf

HSE:  http://www.hse.gov.uk/brexit/ag-scenario-table.pdf

Socio-Economic Assessment of PFHxS and PFHxS-related Substances

Perfluorohexane sulfonic acid (PFHxS) and its salts have been identified as substances of very high concern due to their very Persistent and very Bioaccumulative (vPvB) properties according to Article 57 e) of REACH in July 2017.  PFHxS and related substances may be present in electrical equipment, fire-fighting foams, food contact papers, semiconductors, water/stain-proofing agents, cleaning and polishing products (as surfactants or surface protection agents) and metal plating.  These substances have also been used as raw materials to produce PFAS based products and are also unintentionally produced during industry processes; for example, PFHxS is a known impurity in the production of PFOS. Norway has submitted a proposal to add PFHxS and PFHxS related substances to the Stockholm Convention for Persistent Organic Pollutants.

Risk & Policy Analysts (RPA), together with Arche Consulting have been appointed by the Norwegian Environment Agency to collect information on the uses of PFHxS and PFHxS-related substances, alternatives, substitution costs and a socio-economic analysis for the proposed REACH restriction and for the upcoming Stockholm Convention process.

More information on the survey can be found here

ECHA and the European Commission (DG Environment) are undertaking a study to assess the extent to which SDSs and Exposure Scenarios (ES) provide relevant information for end-use formulators who produce consumer mixtures, specifically regarding the exposure assessments which are required under REACH.

As part of the consultation for this study, formulators of mixtures for consumer use are invited to participate by completing a short questionnaire on their information needs, on experience related to REACH exposure scenarios communicated to them and on carrying out own chemicals safety assessment (if relevant).

This information is vital to the study as it will identify issues and problems and suggest recommendations for improving supply chain communication. 

consortium comprising RPA Risk & Policy Analysts (United Kingdom), FoBiG Forschungs- und Beratungsinstitut Gefahrstoffe (Germany), COWI (Denmark), and EPRD Office for Economic Policy and Regional Development (Poland) has been contracted by the European Commission (DG Employment, Social Affairs and Inclusion) to carry out a study to support a possible amendment of Directive 2004/37/EC on the protection of workers from exposure to carcinogens or mutagens at work.

Stakeholder consultation is being undertaken for this study to collect data and information that will underpin the assessment. This data will be collected through questionnaires developed for specific stakeholder groups. 

The following questionnaires are available:

• Questionnaire 1 for companies whose workers are exposed to cadmium and its inorganic compounds, beryllium and its inorganic compounds, inorganic arsenic compounds, formaldehyde, and 4,4'-Methylene-bis(2-chloroaniline) (MOCA);
• Questionnaire 2 for companies whose workers are exposed to Cr(VI) compounds from welding, plasma cutting, and similar processes that generate fumes;
• Questionnaire 3 for Occupational Health & Safety consultants/experts;
• Questionnaire 4 for Member State authorities that are responsible for setting and/or enforcing national OELs and/or would be able to provide any information, views, and data on the likely impacts of new OELs, STELs and skin notations under the CMD.

The deadline for completion of all questionnaires is 3 November 2017.  If you are interested in completing this questionnaire but need more time, please contact the study team prior to the deadlines given above to agree an individual deadline.

Further information on the study and links to the questionnaires can be found here.

The European Commission (DG GROW) has commissioned RPA (with support from Mayer Brown LLP) to conduct a study to support the Commission’s ex-post evaluation of the Detergents Regulation.  The purpose of this study will be to evaluate the effectiveness, efficiency, coherence, relevance and EU added-value of the Detergents Regulation.

To support our work, we have launched an online open public consultation comprising two separate questionnaires:

1. Questions for EU citizens:  This questionnaire is designed for EU citizens and consumers of detergent products
2. Questions for organisations:  This questionnaire is designed for all other stakeholder groups, including companies, industry associations and sector groups, environmental and consumer NGOs, public authorities and bodies responsible for implementing and/or enforcing the Detergents Regulation

Both questionnaires are available in English, German and French.  Responses must be submitted by Wednesday 12^th July 2017.

Risk & Policy Analysts Ltd (RPA), together with CSES and EPRD, has been contracted by the European Commission (DG Justice) to support the evaluation of the Consumer Rights Directive (Directive 2011/83/EU).   

The Directive on Consumer Rights (2011/83/EU) was adopted in 2011 and had to be transposed into national legislation by the Member States and be applicable from 2014.  The Directive supports a real business-to-consumer (B2C) internal market, striking the right balance between a high level of consumer protection and the competitiveness of enterprises.

The objective of the study is to collect data and information on how the Directive is viewed by consumers and businesses in the following countries:  Bulgaria, Cyprus, Czech Republic, Germany, Estonia, Finland, Greece, France, Ireland, Italy, Lithuania, Netherlands, Poland, Portugal, Romania, Sweden, Slovakia, United Kingdom as well as authorities and ECCs across the EU.

To assist with this study we are inviting consumers, businesses and authorities to complete a short questionnaire by 16 September 2016. 

RPA, together with FoBiG, Milieu, and EPRD, have been contracted by the European Commission to support the evaluation of a possible amendment of Directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens or mutagens at work (CMD).

The preventive and protective measures established by the CMD include the Occupational Exposure Limit Values (OELVs) set out in Annex 3 of the Directive.  New OELVs are being considered for chromium VI compounds, 1,3-butadiene, acrylamide, ethylene oxide, 1,2-epoxypropane, bromoethylene, and a revised OELV is being considered for vinyl chloride monomer. 

The objective of the study is to collect data and information feeding into the assessment of the impacts of the OELVs and, in particular, the evaluation of potential impacts on competitiveness and SMEs.

The deadline for survey completion is 31^st May 2016. 

RPA is pleased to announce the launch of the European Commission’s Open Public Consultation on the regulatory fitness check of chemicals legislation (excluding REACH).  

The Swedish Chemicals Agency (KemI) wishes to prepare a RoHS Annex II dossier for the restriction of use of MCCP in electrical and electronic equipment (EEE), in accordance with Article 6(1) of the RoHS recast Directive (2011/65/EU) and has commissioned Risk & Policy Analysts Ltd (RPA) for support. 

This survey requests information regarding :

• Any use of MCCP or MCCP-containing products (mixtures / articles) that takes place within the EU, including, where available, the respective tonnages; and
• The presence of MCCP in mixtures or EEE articles of non-EU origin which are placed on the EU market.

Information submitted will be handled according to a confidentiality policy, which can be found by clicking here.

The Construction Products Regulation (EU) No 305/2011 (the CPR) was published in April 2011 and repealed the Construction Products Directive (the CPD).  Although the CPR has only recently been implemented, the European Commission (DG ENTR) is keen to assess the extent to which the CPR is meeting (or is likely to meet) its main objectives – based on actual experiences of key stakeholders based on implementation approaches in each Member State. 

A consultation has therefore been launched, aimed at obtaining information to inform policy makers on progress against the CPR objectives, and which will contribute to developing conclusions on whether further actions still need to be taken to ensure the consolidation of the Internal Market for construction products.

The deadline for completion of questionnaires has passed.  The consultation is now closed.

Click here to find out more about this consultation.