With the ‘Ten REACH Tests for ECHA the European Environmental Bureau (EEB) presents a challenge to the European Chemical Agency (ECHA). The tests aim at improving the implementation of REACH by enhancing ECHA’s adherence to REACH’s underlying democratic and environmental principles. These include the precautionary and the polluter-pays principles, the placing of the burden of proof on industry (i.e., industry must prove that substances do not adversely affect health or the environment), upholding the ‘no data, no market’ rule, substitution with safer substances or technologies, as well as transparency.
As the 2020 exercise was welcomed by national authorities, the European Commission and colleagues from other civil society organisations, the EEB has decided to challenge ECHA again with the 2021 Ten REACH Tests for ECHA, outlined below. We focus on activities that the agency did not deliver on during 2020 and include new tests that we hope will help improve ECHA’s performance – and through that improve the protection of people and the environment from the risks posed by hazardous chemicals.