AskREACH letter to European Commission

29 / 04 / 2022

After 4 ½ years of work on the information obligations according to REACH Art. 33, the AskREACH consortium has reported on its experiences in a letter to the EU Commission. The letter is accompanied by a non-exhaustive list of policy options that could help to improve the current situation.

Article 33 of REACH stipulates that suppliers of articles have to communicate information about the presence of substances of very high concern (SVHCs). Actors along supply chains as well as consumers should receive the information they need to ensure safe use of articles containing SVHCs at concentrations above 0.1% weight-by-weight. “Informed purchase decisions” of consumers should provide market incentives for the development and use of safer alternatives instead of SVHCs. The market-based impulses and their anticipation by the supply chain actors is one of the most relevant non-hierarchical innovations in the chemicals regulatory framework, recently further fostered by the development of the SCIP database, which also relies on the contents and quality of information provided in accordance with Article 33 of REACH.

The LIFE AskREACH project has invested a great deal of effort into the development and promotion of IT tools to facilitate communications about SVHCs along the supply chain as well as between suppliers and consumers. Although several surveys have shown that consumers are deeply concerned about the potential negative impact of chemicals in articles, the numbers of SVHC requests submitted by consumers are still very low. The positive effects of Article 33 intended by the legislators are therefore not being realised. The experience gained in LIFE AskREACH suggests that the current regulatory structure is a major cause of this deficiency.

LIFE AskREACH also engages with companies to improve communications along the supply chain. Based on this experience, the project sees an urgent need for the Commission to consider the following policy options (among others) for improving the implementation of Article 33:

  • Measures for improving the quality of supplier responses to consumers
  • Supporting and extending the supplier’s duty to provide information to consumers about SVHCs in articles
  • Shorter period for responding to consumer requests
  • Improved consumer information when shopping on online marketplaces
  • Development and implementation of unique product identifiers to reduce transaction costs for all actors involved


Please find the full text of the letter here.

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