Directions for the REACH revision – CARACAL 54 – ClientEarth comments

The Commission presented the “Key elements, state of play” for the REACH Revision currently under preparation to Member States and Stakeholders at CARACAL-54 on 3 April 2025. ClientEarth thanks the Commission for this opportunity to provide feedback by 25 April.

Our comments on the considerations outlined by the Commission entail recommendations to refine options, so they increase the level of protection of REACH while not missing out on simplification potentials. More details on ClientEarth’s recommendations to future proof REACH can be found in the comments submitted following CARACAL-53 as well as in previous contributions (Demands #1-6 for REACH reform).

ClientEarth supports many options considered, including the introduction of new tools in the context of Registration to enforce the ‘no data no market’ rule. By contrast, the plans to revise the Authorisation regime, linked with new roles for the Candidate List and Analysis of Risk Management Options (RMOA), are particularly concerning as they may fortify existing bottlenecks for regulatory controls, while violating both the objective of REACH to phase-out SVHCs and procedural rights of authorities.