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EDA to assess impact of EU chemical/waste regulations on defence

EDA has just launched a new study to evaluate the impact EU regulations on chemicals and waste might have on the wider defence sector. The results are expected to be available by the end of this year. 

The study does not cover the REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) nor the CLP (Classification, Labelling and Packaging) regulations which have already been assessed in an EDA study in 2016 and whose effects on defence equipment have proven to be significant - from design and manufacturing to in-service use, maintenance and disposal. 

In the new study, due to be delivered in December, the focus will be on other EU regulations related to chemicals which may also have an impact on European defence capabilities, such as:

  • Biocidal Products (BPR)
  • Persistent Organic Pollutants (POP)
  • Ozone Depleting Substances (ODS)
  • Greenhouse Gases (F-GAS)
  • Restriction of Hazardous Substances (RoHS). 

The study will also look into potential repercussions on defence of the recently revised EU Waste Framework Directive (WFD), and specifically its provision under Article 9 on providing information to the European Chemicals Agency (ECHA) database on Substances of Concern in articles as such or In complex Products (SCIP), as from 5 January 2021. 

The study will be carried out by a consortium encompassing Milieu Consulting SPRL (consortium leader) and REACHLAW Oy.


The aim of the study is to provide detailed information on the impact of those EU legislations on the defence sector and to propose recommendations on how defence stakeholders (Ministries of Defence, Armed Forces, defence industry) could deal with them in a more coherent way. 

As part of the study, the contractor will be conducting consultations with a range of relevant stakeholders, such as the European Commission, the European Chemicals Agency (ECHA), Member States’ MoDs, Member States’ competent authorities as well as defence industry stakeholders, including the AeroSpace and Defence Industries Association of Europe (ASD) as well as National Defence Industry Associations (NDIAs).