Kiri

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP

AND SMES

DIRECTORATE-GENERAL FOR ENVIRONMENT

EUROPEAN CHEMICALS AGENCY

Brussels,

GROW.F1/AEA/nt

grow.f.1(2024)5121684

Their Excellencies

The Deputy Permanent

Representatives of the Member

States to the European Union

Sent by email only

Subject: Nomination of members to Committees for Risk Assessment and Socio-

economic Analysis under the REACH Regulation

Your Excellency,

We are writing to address a matter of importance concerning the implementation of our

European chemicals legislation, which falls under the remit of the European Chemicals

Agency (ECHA). Effective implementation is essential for a greener, safer, and more

competitive Europe. It ensures the highest protection against hazardous chemicals and

fosters innovation across Member States, as well as a unified European approach to

chemicals safety. ECHA plays a pivotal role in these processes and relies on the work of

its committees and working groups, in particular the Committees for Risk Assessment

(RAC) and Socio-Economic Analysis (SEAC).

These Committees are pillars of scientific scrutiny and evaluation within the EU's

regulatory framework for chemicals. They deliver transparent, independent, and high-

quality scientific opinions, providing a solid basis for decision-making, contributing to the

protection of human health and the environment, and enabling the free circulation of

chemicals on the internal market. Their role is crucial in regulating chemicals with direct

impact on citizens’ daily life and health (1) and in maintaining the competitiveness of

European industries, by ensuring that the implementation of regulations is consistent,

scientifically robust and economically viable.

We would like to flag the current challenges these committees are facing, in regard to their

functioning and resourcing. The tasks assigned to them over time, and particularly since

2020, have been increasing in complexity and scope, necessitating a diverse array of

expertise and sufficient capacity.

(1) for example bisphenols, lead, glyphosate, chemicals in tattoo inks, microplastics and the current

proposed ban on Per- and polyfluoroalkyl substances (PFAS).

2

According to the EU REACH Regulation2, Committee members are nominated by Member

States, who are required to provide support and technical assistance to the members of the

committees. But ECHA is currently confronted with a historically low level of committees’

membership. Some Member States have not nominated members to these committees. It

is therefore imperative to address this situation, which poses significant challenges to the

committees' ability to fulfil their mandates. In recent years, ECHA’s Management Board,

which includes members representing all EU Member States, as well as the heads of

Member States’ competent authorities have expressed strong concerns in this respect.

Some measures have been taken to enhance the Committees’ efficacy and workability,

including increasing membership and the adequacy of compensation for the authorities

employing the committee members. But despite these joint efforts that the Commission

has undertaken with ECHA, the continued effectiveness of the committees hinges upon the

active engagement and support of Member States.

We are extending our thank you for your valuable contribution to date. At the same time,

we kindly ask all Member States to nominate two candidates per committee, ensure

adequate support for such nominations, and that candidates possess the requisite

qualifications, expertise and working time, to serve as effective and active members.

ECHA stands ready to assist Member States in identifying suitable nominees for RAC and

SEAC, as well as to support members as they carry out their role. Your commitment and

contribution would significantly contribute to the sustainability of the EU’s regulatory

framework for chemicals, the protection of health and the environment, as well as well to

the sustainable competitiveness of the European chemicals industry.

We appreciate your attention to this matter and look forward to your positive response.

Thank you for your cooperation.

Yours sincerely,

(e-sign) (e-sign) (e-sign)

Kerstin Jorna Florika Fink-Hooijer Sharon Mc Guinness

Director-General Director-General Executive Director

DG Internal Market, DG Environment European Chemicals Agency

Industry, Entrepreneurship

and SMEs

Attachment: RAC and SEAC membership per country and extract from the REACH

Regulation

Copies: Members of the Management Board

2 Regulation (EC) No 1907/2006.

3

Attachment: RAC and SEAC membership per country

Country RAC SEAC

Austria 2 members 1 member

Belgium 1 member 1 member

Bulgaria 2 members -

Croatia 2 members 1 member

Cyprus 1 member 2 members

Czechia 1 member -

Denmark 2 members 1 member

Estonia - 1 member

Finland 2 members 1 member

France 2 members 2 members

Germany 2 members 2 members

Greece 2 members 1 member

Hungary 1 member 1 member

Iceland - -

Ireland 1 member 1 member

Italy 2 members 2 members

Latvia 2 members 1 member

Liechtenstein - -

Lithuania 2 members 2 members

Luxembourg 2 members 1 member

Malta - -

Netherlands 2 members 2 members

Norway 2 members 1 member

Poland 2 members -

Portugal 1 member 1 member

4

Country RAC SEAC

Romania 1 member -

Slovak Republic 1 member -

Slovenia 2 members 2 members

Spain 2 members 2 members

Sweden 2 members 1 member

Article 85 of Regulation (EC) No 1907/2006 of the European Parliament and of the

Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and

Restriction of Chemicals (REACH):

“1. Each Member State may nominate candidates to membership of the Committee for

Risk Assessment. The Executive Director shall establish a list of the nominees, which shall

be published on the Agency's website, without prejudice to Article 88(1). The Management

Board shall appoint the members of the Committee from this list, including at least one

member but not more than two from the nominees of each Member State that has

nominated candidates. Members shall be appointed for their role and experience in

performing the tasks specified in Article 77(3).

2. Each Member State may nominate candidates to membership of the Committee for

Socio-economic Analysis. The Executive Director shall establish a list of the nominees,

which shall be published on the Agency's website, without prejudice to Article 88(1). The

Management Board shall appoint the members of the Committee from this list, including

at least one member but not more than two from the nominees of each Member State that

has nominated candidates. Members shall be appointed for their role and experience in

performing the tasks specified in Article 77(3).”

Electronically signed on 09/07/2024 09:55 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP

AND SMES

DIRECTORATE-GENERAL FOR ENVIRONMENT

EUROPEAN CHEMICALS AGENCY

Brussels,

GROW.F1/AEA/nt

grow.f.1(2024)5121684

Their Excellencies

The Deputy Permanent

Representatives of the Member

States to the European Union

Sent by email only

Subject: Nomination of members to Committees for Risk Assessment and Socio-

economic Analysis under the REACH Regulation

Your Excellency,

We are writing to address a matter of importance concerning the implementation of our

European chemicals legislation, which falls under the remit of the European Chemicals

Agency (ECHA). Effective implementation is essential for a greener, safer, and more

competitive Europe. It ensures the highest protection against hazardous chemicals and

fosters innovation across Member States, as well as a unified European approach to

chemicals safety. ECHA plays a pivotal role in these processes and relies on the work of

its committees and working groups, in particular the Committees for Risk Assessment

(RAC) and Socio-Economic Analysis (SEAC).

These Committees are pillars of scientific scrutiny and evaluation within the EU's

regulatory framework for chemicals. They deliver transparent, independent, and high-

quality scientific opinions, providing a solid basis for decision-making, contributing to the

protection of human health and the environment, and enabling the free circulation of

chemicals on the internal market. Their role is crucial in regulating chemicals with direct

impact on citizens’ daily life and health (1) and in maintaining the competitiveness of

European industries, by ensuring that the implementation of regulations is consistent,

scientifically robust and economically viable.

We would like to flag the current challenges these committees are facing, in regard to their

functioning and resourcing. The tasks assigned to them over time, and particularly since

2020, have been increasing in complexity and scope, necessitating a diverse array of

expertise and sufficient capacity.

(1) for example bisphenols, lead, glyphosate, chemicals in tattoo inks, microplastics and the current

proposed ban on Per- and polyfluoroalkyl substances (PFAS).

2

According to the EU REACH Regulation2, Committee members are nominated by Member

States, who are required to provide support and technical assistance to the members of the

committees. But ECHA is currently confronted with a historically low level of committees’

membership. Some Member States have not nominated members to these committees. It

is therefore imperative to address this situation, which poses significant challenges to the

committees' ability to fulfil their mandates. In recent years, ECHA’s Management Board,

which includes members representing all EU Member States, as well as the heads of

Member States’ competent authorities have expressed strong concerns in this respect.

Some measures have been taken to enhance the Committees’ efficacy and workability,

including increasing membership and the adequacy of compensation for the authorities

employing the committee members. But despite these joint efforts that the Commission

has undertaken with ECHA, the continued effectiveness of the committees hinges upon the

active engagement and support of Member States.

We are extending our thank you for your valuable contribution to date. At the same time,

we kindly ask all Member States to nominate two candidates per committee, ensure

adequate support for such nominations, and that candidates possess the requisite

qualifications, expertise and working time, to serve as effective and active members.

ECHA stands ready to assist Member States in identifying suitable nominees for RAC and

SEAC, as well as to support members as they carry out their role. Your commitment and

contribution would significantly contribute to the sustainability of the EU’s regulatory

framework for chemicals, the protection of health and the environment, as well as well to

the sustainable competitiveness of the European chemicals industry.

We appreciate your attention to this matter and look forward to your positive response.

Thank you for your cooperation.

Yours sincerely,

(e-sign) (e-sign) (e-sign)

Kerstin Jorna Florika Fink-Hooijer Sharon Mc Guinness

Director-General Director-General Executive Director

DG Internal Market, DG Environment European Chemicals Agency

Industry, Entrepreneurship

and SMEs

Attachment: RAC and SEAC membership per country and extract from the REACH

Regulation

Copies: Members of the Management Board

2 Regulation (EC) No 1907/2006.

3

Attachment: RAC and SEAC membership per country

Country RAC SEAC

Austria 2 members 1 member

Belgium 1 member 1 member

Bulgaria 2 members -

Croatia 2 members 1 member

Cyprus 1 member 2 members

Czechia 1 member -

Denmark 2 members 1 member

Estonia - 1 member

Finland 2 members 1 member

France 2 members 2 members

Germany 2 members 2 members

Greece 2 members 1 member

Hungary 1 member 1 member

Iceland - -

Ireland 1 member 1 member

Italy 2 members 2 members

Latvia 2 members 1 member

Liechtenstein - -

Lithuania 2 members 2 members

Luxembourg 2 members 1 member

Malta - -

Netherlands 2 members 2 members

Norway 2 members 1 member

Poland 2 members -

Portugal 1 member 1 member

4

Country RAC SEAC

Romania 1 member -

Slovak Republic 1 member -

Slovenia 2 members 2 members

Spain 2 members 2 members

Sweden 2 members 1 member

Article 85 of Regulation (EC) No 1907/2006 of the European Parliament and of the

Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and

Restriction of Chemicals (REACH):

“1. Each Member State may nominate candidates to membership of the Committee for

Risk Assessment. The Executive Director shall establish a list of the nominees, which shall

be published on the Agency's website, without prejudice to Article 88(1). The Management

Board shall appoint the members of the Committee from this list, including at least one

member but not more than two from the nominees of each Member State that has

nominated candidates. Members shall be appointed for their role and experience in

performing the tasks specified in Article 77(3).

2. Each Member State may nominate candidates to membership of the Committee for

Socio-economic Analysis. The Executive Director shall establish a list of the nominees,

which shall be published on the Agency's website, without prejudice to Article 88(1). The

Management Board shall appoint the members of the Committee from this list, including

at least one member but not more than two from the nominees of each Member State that

has nominated candidates. Members shall be appointed for their role and experience in

performing the tasks specified in Article 77(3).”

Electronically signed on 09/07/2024 09:55 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË – Tel. +32 22991111

EUROPEAN COMMISSION DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP

AND SMES

DIRECTORATE-GENERAL FOR ENVIRONMENT

EUROPEAN CHEMICALS AGENCY

Brussels,

GROW.F1/AEA/nt

grow.f.1(2024)5121684

Their Excellencies

The Deputy Permanent

Representatives of the Member

States to the European Union

Sent by email only

Subject: Nomination of members to Committees for Risk Assessment and Socio-

economic Analysis under the REACH Regulation

Your Excellency,

We are writing to address a matter of importance concerning the implementation of our

European chemicals legislation, which falls under the remit of the European Chemicals

Agency (ECHA). Effective implementation is essential for a greener, safer, and more

competitive Europe. It ensures the highest protection against hazardous chemicals and

fosters innovation across Member States, as well as a unified European approach to

chemicals safety. ECHA plays a pivotal role in these processes and relies on the work of

its committees and working groups, in particular the Committees for Risk Assessment

(RAC) and Socio-Economic Analysis (SEAC).

These Committees are pillars of scientific scrutiny and evaluation within the EU's

regulatory framework for chemicals. They deliver transparent, independent, and high-

quality scientific opinions, providing a solid basis for decision-making, contributing to the

protection of human health and the environment, and enabling the free circulation of

chemicals on the internal market. Their role is crucial in regulating chemicals with direct

impact on citizens’ daily life and health (1) and in maintaining the competitiveness of

European industries, by ensuring that the implementation of regulations is consistent,

scientifically robust and economically viable.

We would like to flag the current challenges these committees are facing, in regard to their

functioning and resourcing. The tasks assigned to them over time, and particularly since

2020, have been increasing in complexity and scope, necessitating a diverse array of

expertise and sufficient capacity.

(1) for example bisphenols, lead, glyphosate, chemicals in tattoo inks, microplastics and the current

proposed ban on Per- and polyfluoroalkyl substances (PFAS).

2

According to the EU REACH Regulation2, Committee members are nominated by Member

States, who are required to provide support and technical assistance to the members of the

committees. But ECHA is currently confronted with a historically low level of committees’

membership. Some Member States have not nominated members to these committees. It

is therefore imperative to address this situation, which poses significant challenges to the

committees' ability to fulfil their mandates. In recent years, ECHA’s Management Board,

which includes members representing all EU Member States, as well as the heads of

Member States’ competent authorities have expressed strong concerns in this respect.

Some measures have been taken to enhance the Committees’ efficacy and workability,

including increasing membership and the adequacy of compensation for the authorities

employing the committee members. But despite these joint efforts that the Commission

has undertaken with ECHA, the continued effectiveness of the committees hinges upon the

active engagement and support of Member States.

We are extending our thank you for your valuable contribution to date. At the same time,

we kindly ask all Member States to nominate two candidates per committee, ensure

adequate support for such nominations, and that candidates possess the requisite

qualifications, expertise and working time, to serve as effective and active members.

ECHA stands ready to assist Member States in identifying suitable nominees for RAC and

SEAC, as well as to support members as they carry out their role. Your commitment and

contribution would significantly contribute to the sustainability of the EU’s regulatory

framework for chemicals, the protection of health and the environment, as well as well to

the sustainable competitiveness of the European chemicals industry.

We appreciate your attention to this matter and look forward to your positive response.

Thank you for your cooperation.

Yours sincerely,

(e-sign) (e-sign) (e-sign)

Kerstin Jorna Florika Fink-Hooijer Sharon Mc Guinness

Director-General Director-General Executive Director

DG Internal Market, DG Environment European Chemicals Agency

Industry, Entrepreneurship

and SMEs

Attachment: RAC and SEAC membership per country and extract from the REACH

Regulation

Copies: Members of the Management Board

2 Regulation (EC) No 1907/2006.

3

Attachment: RAC and SEAC membership per country

Country RAC SEAC

Austria 2 members 1 member

Belgium 1 member 1 member

Bulgaria 2 members -

Croatia 2 members 1 member

Cyprus 1 member 2 members

Czechia 1 member -

Denmark 2 members 1 member

Estonia - 1 member

Finland 2 members 1 member

France 2 members 2 members

Germany 2 members 2 members

Greece 2 members 1 member

Hungary 1 member 1 member

Iceland - -

Ireland 1 member 1 member

Italy 2 members 2 members

Latvia 2 members 1 member

Liechtenstein - -

Lithuania 2 members 2 members

Luxembourg 2 members 1 member

Malta - -

Netherlands 2 members 2 members

Norway 2 members 1 member

Poland 2 members -

Portugal 1 member 1 member

4

Country RAC SEAC

Romania 1 member -

Slovak Republic 1 member -

Slovenia 2 members 2 members

Spain 2 members 2 members

Sweden 2 members 1 member

Article 85 of Regulation (EC) No 1907/2006 of the European Parliament and of the

Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and

Restriction of Chemicals (REACH):

“1. Each Member State may nominate candidates to membership of the Committee for

Risk Assessment. The Executive Director shall establish a list of the nominees, which shall

be published on the Agency's website, without prejudice to Article 88(1). The Management

Board shall appoint the members of the Committee from this list, including at least one

member but not more than two from the nominees of each Member State that has

nominated candidates. Members shall be appointed for their role and experience in

performing the tasks specified in Article 77(3).

2. Each Member State may nominate candidates to membership of the Committee for

Socio-economic Analysis. The Executive Director shall establish a list of the nominees,

which shall be published on the Agency's website, without prejudice to Article 88(1). The

Management Board shall appoint the members of the Committee from this list, including

at least one member but not more than two from the nominees of each Member State that

has nominated candidates. Members shall be appointed for their role and experience in

performing the tasks specified in Article 77(3).”

Electronically signed on 09/07/2024 09:55 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121