EEB REACH REFIT POSITION PAPER

We are deeply concerned by the Commission’s decision to carry out this REACH review as a REFIT evaluation under its Better Regulation Agenda. The REFIT evaluation is focused on reducing the burdens on industry rather than reducing the burdens on health and the environment caused by chemical substances. Indeed, one of the main pillars of REACH is the polluter pays principle, meaning that the companies placing chemical pollution in the environment are responsible for any costs, not society. The REFIT exercise so far mainly considers the direct costs to companies in complying with the different pieces of legislation rather than the benefits for society of well implemented health and environmental legislation. But there are tradeoffs between these two objectives. It is obvious that in most cases the best protection against chemical pollution also has the highest regulatory costs and the other way around. Who should bear the costs? If industry regulatory costs are reduced, the costs will then be borne by taxpayers or through loss in health, human lives and degraded ecosystems…