Comments on the draft recommendation of substances for inclusion in Annex XIV

Lead
231-100-4

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 I. Personal information

Note: Personal information is never disclosed to the public

 II. Organisation

Are you submitting information: *

On behalf of a Member State Competent Authority
As an Individual
On behalf of an organisation or institution

Confidentiality

The consultation is subject to data privacy rules (see https://echa.europa.eu/legal-notice). Comments provided in Sections 'III. Non-confidential comments' and 'IV. Non-confidential Attachment' of this webform will be made available to the public. It is the interested parties' responsibility to ensure that no confidential information is included in Sections III and IV (including the name of your organisation). Confidential information must be submitted in form of a confidential attachment (see Section 'V. Confidential Attachment' below), which will only be made available to ECHA, including its Committees, the Member State competent authorities and to the European Commission.

 III. Non-confidential comments on ECHA's draft recommendation

To ensure the information you provide is relevant for ECHA's Member State Committee, which provides an opinion on ECHA's draft recommendation, and for ECHA's recommendation, it is advised to read the documents describing the general approaches used for prioritisation of SVHCs and for preparation of draft Annex XIV entries.

Comment submitters are also advised to read ECHA's general responses on issues commonly raised in consultation on draft recommendations. The document describes which information is relevant to this step of the authorisation process and also clarifies what type of information cannot be considered by ECHA at this step of the authorisation process including the reasoning. The document has been developed by compiling in a consolidated form responses provided to address individual comments submitted in past consultations.

It is to be stressed that ECHA does not consider at this phase of the process information on topics such as the availability and suitability of alternatives, socio-economic considerations regarding the benefits of a use or the (adverse) impacts of ceasing a use or the level of risk associated to a particular use. Information regarding these topics should be provided as part of an application for authorisation in case the substance is included in Annex XIV.

Also please note that there is a separate call for information where the European Commission invites information on the possible socio-economic consequences of subjecting the substance to the authorisation requirement (see the separate web-form under "Details" for the substance of interest).

Prioritisation and general issues
Comments on the prioritisation results and general issues:

HINTS

  • for details on the approach used by ECHA for determining the priority of the SVHCs for inclusion in Annex XIV, and the type of information relevant for this step of the recommendation process, it is advised to read the following documents:
  • information relevant for prioritisation of substances includes types of uses in the scope of authorisation (e.g. uses by professionals or consumers / uses in articles), volumes for those uses, and where relevant the potential that other substances on the Candidate List could substitute / be substituted by the substance in some uses;
  • REACH registrations are the main source of information for ECHA's assessment. Registrants are therefore strongly advised to update their registration dossiers with any new relevant information. Registration updates (as of the last day of the consultation) will be taken into account by ECHA when finalising its recommendation;
  • any information on uses provided in the consultation should allow assessing its reliability and representativeness. Therefore, information should be accompanied by a description which clarifies the source of the information, the time period covered, the sector(s) / the share of the market / the number of users it represents and any other description which is relevant for the assessment of the reliability and representativeness of the information;
  • when commenting, if relevant, please add the title of the document (e.g. substance's background document or prioritisation results) and page number you are referring to in front of your comment.

Transitional arrangements
Comments on the proposed Latest Application (LAD) and Sunset dates:

HINTS:

  • for details on the approach used by ECHA for determining the proposed Latest Application Dates and Sunset Dates, and the type of information relevant for this step of the recommendation process, it is strongly advised to read the following documents:
  • please note that the present lack of alternatives to (some of) the uses of a substance or the time estimated to change industrial processes and finalise transition to alternatives is no viable reason for prolonging the application dates or sunset dates for the substance or some of its uses. Such information is however important information to be included in a potential authorisation application, if the substance is included in Annex XIV.

Uses exempted from the authorisation requirement
Comments on uses (or categories of uses) that should be exempted, including reasons for that:

HINTS:

  • for details on the approach used by ECHA for assessing exemption requests, and the type of information relevant for this step of the recommendation process, it is advised to read the following documents:
  • Before making a request for exemption from authorisation under Art. 58(2) for a particular use, it is strongly recommended to take into account ECHA's previous responses to Art. 58(2) exemption requests. It is noted that any Art. 58(2) request is assessed case-by-case.
  • when commenting: mention clearly the use(s) or categories of uses that are proposed to be exempted and the Community legislation that is considered to justify the proposed exemption(s)
  • if a use falls under the generic exemptions from authorisation, there is no need to propose an additional specific exemption.

 IV. Attachment (additional non-confidential information) to comments on ECHA's draft recommendation

Please attach additional non-confidential information below. ECHA makes this information publicly available.

Please provide your main comment(s) in the respective fields of Section III. Attachments in Section IV are exclusively reserved for additional information. Please avoid repetition of comments given already in Section III of this webform.

Maximum file size is 10 MB

If you would like to submit more than one document, please create a zip archive where you include all files and upload the zip file as attachment.

 V. Confidential Attachment to comments on ECHA's draft recommendation

Please attach confidential information below. Confidential information will only be used by ECHA, including its Committees, by the Member State competent authorities and by the European Commission. Therefore, any confidential information cannot benefit from stakeholder involvement. If you upload a confidential attachment, please fill in the information to justify the confidentiality. This will facilitate ECHA's work if it receives requests for access to documents. In addition, please also submit a version/summary containing the non-confidential parts in Section IV.

Please provide your main comment(s) in the respective fields of Section III of this webform. Attachments in this section should be exclusively reserved for confidential information. Please avoid repetition of comments given already in Section III of this webform.

Maximum file size is 10 MB

If you would like to submit more than one document, please create a zip archive where you include all files and upload the zip file as attachment.

I have the following reasons enumerated in Article 4(1) or 4(2) of Regulation (EC) No 1049/2001 regarding public access to documents why the information submitted as confidential cannot be disclosed to persons requesting access to documents (please explain in the commenting field below those reasons; For example a reason could be that the protection of your commercial interests, including intellectual property, would be undermined).

No confidential information of any kind should be included: