Position paper – REACH revision: The automotive industry perspective

The automotive industry has successfully worked towards the objectives of Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). For many years, however, we have realised several shortcomings that would benefit from introducing various amendments. We therefore welcome the opportunity to support the upcoming targeted REACH revision.

Our sector is having several roles under REACH, including the importer, distributor, producer of articles, and downstream user. In addition, our main role, which is the assembler of articles into highly complex objects, is not covered by REACH definitions.

Considering our extensive global supply chain, the intricate nature of our products as complex objects, and the necessity for sustained market availability for repairs, the execution of REACH presents significant difficulties. Consequently, we aim to outline our challenges and propose solutions to enhance the REACH process.

Together, these proposals aim to improve the effectiveness, clarity, and proportionality of REACH, while supporting innovation, circularity, and the long-term competitiveness of EU automotive industry.

1. Make the Risk Management Option Analysis (RMOA) mandatory
   To avoid inconsistent and overlapping regulation, harmonised hazard classification should be a prerequisite for any RMOA.
2. Improve the Authorisation process
   Authorisation and Restriction processes should be merged to create a fairer, more workable system.
3. Improve the Restriction process
   A more workable, risk-based, and sector-specific restriction system with clear identifiers, practical derogations, and reduced unnecessary reporting is needed.
4. Substances and mixtures
   To reduce administrative burden and improve regulatory clarity, we should rely exclusively on correct mixture classification and existing occupational and environmental controls.
5. Digital Product Passports (DPPs)
   DPPs should not become mandatory under REACH, as existing industry systems already ensure effective compliance and supply-chain communication.
6. Improve data quality and data exchange
   Data quality must be strengthened by mandating structured digital Safety Data Sheets and full disclosure of any regulated substances they contain.

You can download ACEA's full position paper here.

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