New REACH Guide on Authorization Applications

The European Commission has published a 120 page guide on how to file an authorization application in anticipation of the first listing of chemicals under Article XIV here

You better be prepared for a lot of work to justify continuing to use a chemical on the authorization list.  In addition to describing the use you want to maintain, you need to submit:

- a chemical safety report

- ?an analysis of alternatives considering their risks and the technical and economic feasibility of substitution and including, if appropriate information about any relevant research and development activities by the applicant.  Gathering information for this will certainly be a challenge.

- a substitution plan including a timetable for proposed actions by the applicant for those alternatives

- if you are arguing there isn't a risk with the use, prove it

- a socio-economic analysis if you are arguing the benefits outweigh the risks

The first list of chemicals selected from the Substances of Very High Concern Candidates will be published next week. Expected: musk xylene, MDA, phthalates DBP, BBP and DEHP and flame retardant HBCDD.  Each will get a "sunset" date after which all uses are banned unless a use is specifically authorized.

Warning to exporters to Europe: it appears that Only Representatives cannot file authorization applications for you.  You will have to work with your supply chain to protect your uses.