Position paper – Essential uses

As part of the Chemical Strategy for Sustainability (CSS), a number of legislative and non-legislative measures with wide-ranging impacts on the auto industry are planned. These include amendments which will affect how the REACH Regulation is applied.

In response to the consultation by the Competent Authorities for REACH and CLP (CARACAL), the European Automobile Manufacturers’ Association (ACEA), the Motorcycle Industry in Europe (ACEM), the European Association of Automotive Suppliers (CLEPA), the European Tyre and Rubber Manufacturers’ Association (ETRMA), the Japan Auto Parts Industries’ Association (JAPIA) and the Korea Automobile Manufacturers’ Association (KAMA) have developed a joint position on ‘essential uses’.

The CSS outlines that the European Commission will “define criteria for essential uses to ensure that the most harmful chemicals are only allowed if their use is necessary for health, safety or is critical for the functioning of society and if there are no alternatives that are acceptable from the standpoint of environment and health. These criteria will guide the application of essential uses in all relevant EU legislation for both generic and specific risk assessments.”

The determination of these criteria and the definition of ‘essential uses’ will have a decisive impact on the industry. ACEA, ACEM, CLEPA, ETRMA, JAPIA and KAMA therefore believe that it is of the utmost importance to provide a balanced and clear definition of the criteria for the notion of ‘essential use’, and that this should be one of the first steps undertaken as part of the CSS.

One of the first steps of the Chemical Strategy for Sustainability should be to provide a balanced and clear definition of the criteria for the notion of ‘essential use’.


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