10 tests for the European Chemicals Agency ECHA

This is an assessment of the European Chemicals Agency (ECHA) by the European Environmental Bureau (EEB), the largest network of environmental citizens’ organisations in Europe.

The Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation is the EU flagship regulation on chemicals. It is based on key EU democratic and environmental principles that need to be implemented in order to ensure that human health and the environment are protected against the risks posed by hazardous chemicals.

The ECHA is responsible for the management and the technical, scientific and administrative aspects of REACH. We appreciate that ECHA cannot make decisions on its own. Nonetheless, the agency can still have considerable impact and influence on chemicals control in Europe, for example through the priority and profile it gives to specific chemicals and through the way in which it chairs discussions and develops opinions.

This test aims to measure progress on and improve the implementation of REACH by enhancing ECHA’s adherence to REACH’s underlying principles, such as the precautionary principle, the allocation of the burden of proof on industry that substances do not adversely affect health or the environment, upholding the ‘no data, no market’ rule,  substitution to safer substance or technology and transparency.

Our assessment is based on the ECHA 10 Tests we presented to ECHA in March 2020. The EEB challenged ECHA with the following ten activities to be performed in 2020. We consider the delivery of these activities as indicators of ECHA’s commitment towards implementing REACH’s underlying democratic and environmental principles. Success depends on many factors, often highly affected by external events and Commission priorities. Our assessment therefore focuses both on effort and result.

During this process, the EEB has opened a cooperative dialogue with ECHA to discuss its performance. We would like to acknowledge and express our appreciation to the agency for its openness to a frank and open exchange of views during the exercise.