A Review of Critical Issues with respect to EU REACH

This study begins with a review of the key features of current European Union’s chemical regulation REACH concerning the Registration, Evaluation, Authorization and Restriction of Chemicals. Under REACH, the industry including manufacturers, importers, or downstream users, but not regulators, has responsibility to ensure the chemical safety and the industry must conduct the risk assessment to trade with the EU market. We particularly selected some aspects of the EU competition law violation risks and enforcement and penalties for non-compliance because the companies affected by REACH are likely to be interested in. We reviewed a very efficient mechanism for data sharing and cost sharing through SIEFs to comply with REACH, and continued to review the EU competition law violation risks through participation in a SIEF or consortium and the enforcement regime and types of penalties made in the EU Member States. This study concludes with a brief discussion of the global impact of REACH on Asian countries including China, Japan, and Korea.