
Restriction is a powerful tool which holds great promise for mitigating exposures to hazardous substances in the EU. However, the restriction process is not the nimble and efficient policy tool that the REACH framers intended. In this report, we describe several important shortcomings of the restriction process as implemented today. It is worth noting that these shortcomings do not bear only on REACH, but also weaken the ability of restriction to support other high-level EU goals like the non-toxic environment strategy and the circular economy. We also outline recommendations for improvement to be considered under the current REACH review.
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