DUCC acknowledges that assessment of alternatives can be a difficult topic. We also believe that downstream users have not been adequately involved in the current process, which in fact contributes to the difficulties authorities face when trying to obtain all the required information. We thus wish to engage on this issue, because, to avoid unintended impacts on EU Society, a robust Assessment of Alternatives is key to making good decisions.
A kick-off workshop took place on the 9th March. The aim of the workshop was to begin the exchange and have a constructive, technical discussion. To focus on the criteria and process and address the importance of AoA as a key building block for the success of the REACH process. DUCC understands that MS have difficulties with AoA in the Authorisation and Restriction step and MS were thus asked to share their experience.
Based on the input received in the first workshop DUCC proceeded with a second workshop on the 24th April. Workshop number 2 progressed the discussion that began briefly at the workshop on the 9th March (see summary notes below) on what would a technical body that supports on assessment of alternatives look like? Financing? Role of industry associations? Dealing with multiple substances and uses?
Topics of interest to be considered for next workshops: Supplier – customer communication around alternatives. Technical equivalence – how to define technical equivalence? Meant as technical sufficiency and considering what is an acceptable loss of performance?