Uncertainties in the New System

Uncertainties in the new system and costs of registration are likely to cause a rationalisation of chemicals on the EU market. The number 

As a separate mechanism, any substance that is identified as a potential candidate for authorisation (i.e., a SVHC on the candidate list ) present in a produced or imported article will need to be notified if 1 tonne per year57 - i.e., the Agency will need to be informed of its presence in the article. For all product types, the presence of 

56 This figure corresponds to approximately 2 % of all substances manufactured or imported above the level of 1 tonne per year in the EU [278]. 

57 An exception applies if the substance has already been registered for that particular use - irrespective of supply chain. 

REACH has therefore become more evenly balanced in terms of its requirements for substances manufactured in the EU and substances in articles that are imported from outside the EU. Non-EU producers of articles will not need to register all the raw materials and processing chemicals used during production, as their EU-counterparts will need to do. Major questions therefore concern what constitutes intentional release, how imports will be monitored and enforced, how many substances may be placed on the candidate list for authoirsation as SVHC, how the European Commission may propose to adapt the legislation, and how the Agency will execute its given powers. 

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