By reducing the amount and detail of information that industry is required to provide on a chemical’s uses and exposure, it would not be possible to carry out a proper risk assessment or to define safe uses. Furthermore, producer responsibility would be passed on to the users of chemicals, thereby undermining a key principle of REACH.

Many important long-term health tests would no longer be compulsory, as industry would be able to argue – on the basis of poor quality information – that there was no relevant exposure. Besides, the substitution principle would be further undermined as authorisations would be granted for an unlimited duration, thereby removing any incentive for companies to develop safer alternatives.

REACH was originally conceived to close the knowledge gap on chemicals and establish a much more effective and coherent system for a safer chemicals management. The German proposals would render REACH unable to deliver on its original aims – improved protection of environment and human health. Therefore WWF urges the UK Presidency to reject the German proposals.