A study by EDA has concluded that considering the complexity of defence supply chains and long lifecycles of military equipment, REACH (and associated CLP) regulation, as they stand now, may impact the actual operability of Member States’ Armed Forces.
EDA outsourced a dedicated study to examine what impact the EU’s regulations on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and on the Classification, Labelling and Packaging of chemical substances and mixtures (CLP) have had on the European defence sector (governments and industry) since they entered into force in 2007 and 2009 respectively. Further to assessing the impact of REACH (and associated CLP) regulation on defence, the study aimed to develop recommendations for further improvement of REACH regulation and its current implementation regime.
The basis for the study, which was finalised in December 2016, aimed for a win-win solution achieving two principle goals: a high level of health and environmental protection, as well as ensuring the operational effectiveness of Member States’ Armed Forces and enhancing the competitiveness and innovation of the European Defence Technological and Industrial Base.
The study’s consultation facilitated input from a wide range of European defence stakeholders including, in particular, the EDA Member States’ Ministries of Defence (MoD), European Commission, European Chemicals Agency (ECHA), Member States’ Competent Authorities on REACH and CLP and the defence industry.
The main conclusions propose several improvements and related actions for stakeholders, broadly grouped into the three main areas:
- More time and resources (for innovative substitution of Substances of Very High Concern);
- Consistency of REACH, other EU laws and policies;
- EU-level solutions for defence under REACH.
EDA has informed the competent stakeholders (Member States’ MoDs, European Commission, ECHA and the defence industry) on the outcome of the study and is now in the process to further liaise with them, and to support further examination and implementation of the study proposals.
The study recommendations addressed to the Commission also serve as EDA input to the upcoming Commission review of the REACH regulation in 2017.