On 30th November 2020, following discussion of REACH Review Action 3 in the 37th meeting of CARACAL (Competent Authorities for REACH and CLP) on 17th November, DUCC has submitted written comments reiterating its commitment to the improvement of supply chain communication and to implementing and building on the tools already developed in the ENES (Exchange Network on Exposure Scenarios) community through the efforts of DUCC members among others.
DUCC supports the general direction of the REACH Review Action 3 development plan and welcomes the promotion of the Sector Use Maps in particular. DUCC stresses the need for a 'proof of concept' phase and to develop the business case for the proposed way forward – especially concerning mechanisms for electronic exchange of (extended) safety data sheet information. Any decision on a strategy to ensure implementation of new digital solutions in the market can only be taken on the basis of a favourable assessment of the benefits versus the costs (not purely financial).
To download the DUCC comments click here.