Accredited stakeholder workshop 2016 : proceedings : Brussels, 21 October 2016.
Date: 2016-12-12
Institutions: European Chemicals Agency
Subjects: EC Regulation, European Chemicals Agency, chemical industry, chemical product, chemistry, conference proceedings, dangerous substance, environmental protection, environmental risk prevention, health risk, scientific research

Accredited Stakeholder 
Workshop 2016 - Proceedings 

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21 October 2016 

Accredited Stakeholder 
Workshop 2016 

Proceedings 
Brussels, 21 October 2016 

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LEGAL NOTICE 

The opinions expressed in this document may not reflect an official position of the 
European Chemicals Agency or the organisations that participated in the workshop. 

Workshop Proceedings – Accredited Stakeholder Workshop 2016 

Reference:  ECHA-16-R-22-EN 
Catalog Number: ED-AK-17-001-EN-N 
ISBN: 978-92-9495-679-8 
ISSN: 2315-2818
DOI: 10.2823/010809 
Publication date: November 2016 
Language: EN 
© European Chemicals Agency, 2016 
Cover page © European Chemicals Agency 

Reproduction is authorised provided the source is fully acknowledged in the form “Source: 
European Chemicals Agency, http://echa.europa.eu”, and provided written notification is 
given to the ECHA Communications Unit (publications@echa.europa.eu). 

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1 Summary 

Once a year, ECHA arranges a 
strategic workshop for its 
accredited stakeholder 
organisations. This is a platform 
to discuss topical issues and 
give recommendations for 
future improvements. All of 
ECHA’s 100 accredited 
stakeholder organisations were 
invited. Altogether, 48 
stakeholder representatives 
registered and 35 participated 
on the day. 

This year, the event’s focus was 
on how to reach the 2020 
global goal for sustainable 
development – the sound management of chemicals throughout their lifecycle. The aim 
is that by 2020, chemicals are used and produced in ways that lead to the minimisation 
of significant adverse effects on human health and the environment.  

ECHA had prepared a draft document describing the twelve main success factors and 
nineteen measures that would contribute to the achievement of this global goal. The 
success factors and measures were critically reviewed and discussed during the 
workshop. Stakeholders also proposed new success factors and measures where they 
felt that important issues had been missed. They were then asked to prioritise the five 
most important ones. The stakeholders also discussed measures that they were 
committed to take to contribute to the achievement of the goals.  

The success factors and measures will be revised based on the feedback from the 
workshop, and presented to the Member States Competent Authorities and then ECHA’s 
Management Board later in the year.  They will then form the basis of ECHA’s strategic 
planning for the coming years.  

2 Participants 

The workshop was attended by 35 representatives from 31 accredited stakeholder 
organisations, representing industry, civil society and academia. 

The following directors participated from ECHA: Geert Dancet, Executive Director; Jukka 
Malm, Deputy Executive Director; Jack de Bruijn, Director of Risk Assessment; Leena 
Ylä-Mononen, Director of Evaluation and Christel Musser, Director of Registration. In 
addition, ECHA’s Communications Unit staff attended to facilitate the breakout groups 
and to take care of practical arrangements.  

A list of participants is available in Annex 1. 

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3 Content and conclusions of the workshop 

The workshop’s main aim was to get an understanding from stakeholders about what 
success would look like if Europe is to achieve the global goal of the sound management 
of chemicals and the minimisation of their adverse effects. ECHA had sent in advance a 
draft document listing 12 success factors and 19 measures that would be necessary for 
success. The aim was also to get their commitment to measures that they can take to 
contribute to success. The document is at Annex 5. 

The day comprised interactive sessions which gave the stakeholders a possibility to 
openly express and discuss their views and reach shared priorities. 

Opening  

Jukka Malm opened the workshop. He welcomed the participants, highlighted current hot 
topics for ECHA and gave an overview of last year’s workshop and how its 
recommendations had been followed up by ECHA. His presentation is available in Annex 
3. The 2015 workshop had concluded with recommendations on three topics: improving 
efficiency, alternatives to animal testing and input to ECHA’s report on REACH and CLP. 
Participants received a document with shared recommendations and ECHA’s follow-up. 
The document is available in Annex 6.  

Morning breakout groups 

The discussions in the morning took 
place in three mixed breakout groups. 
The main questions were: Are our 
success factors and measures the right 
ones? Do they need to be expressed 
differently? Are any missing? Which are 
the five most important to your 
organisation? 

All three breakout groups first 
discussed the success factors, proposed 
new ones and then voted for the most 
important ones for them. Then they 
discussed the measures, judged their importance and achievability, proposed new ones 
and finally voted again for their most important ones. The voting was done with stickers 
in different colours. This way, ECHA could see the favoured success factors and 
measures for industry and civil society and take both views into account when analysing 
the results further.  

The results (top 5 most important 
success factors and top 5 measures 
compiled from all groups) were 
presented to the plenary after the 
lunch.  

In the stakeholders’ view, the most 
important success factors to reach the 
2020 goals were the following:  

•  Companies experience firm and 

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fair enforcement: 16 votes 

Information about substances flows in the supply chain: 13 votes 

•  The REACH & CLP experience is shared world-wide: 14 votes 
• 
•  Non-animal testing methods are the standard: 13 votes 
• 
Information on chemicals is freely available: 12 votes 

In addition, they proposed new success factors: 

-  The innovation and competitiveness of EU companies is ensured and enhanced;  
-  Companies are supported in their efforts to innovate and substitute dangerous 

chemicals, to help avoid regrettable substitution; and  

-  Member States play an active role in promoting and supporting innovation and 

substitution. 

The five most important measures were the following: 

-  Substitution is promoted: 19 votes 
-  Promotion of internationally harmonised methodologies and tools at OECD and 

other international fora: 16 votes 

-  The use of supply chain communications tools: 15 votes 
-  Chemicals data used for other EU legislation: 13 votes 
-  Coordinated and equal enforcement: 10 votes 

In addition, new measures were proposed: 

-  Providing incentives to promote compliance 
-  Simplifying the effort required to prove a company’s SME status 
- 
-  Level playing fields for all authorisation applicants in terms of review periods 
-  ECHA, Member State and Commission funded research programmes to promote 

Including a new category for SME company size  

innovative and sustainable chemicals and processes to avoid regrettable 
substitution 

-  Measures to achieve more effective phase-out of chemicals of concern through 

fit-for-purpose restriction dossiers  

-  Create a system to share data in the supply chain and follow-up on market 

disruption 

Overall, many stakeholders commented that the current drafting of the measures 
needed to be much more understandable and less ECHA focussed for non-experts.   

Afternoon breakout groups 

In the afternoon, participants were 
divided into sectoral groups: one 
breakout group for civil society 
organisations and two for industry 
associations. The groups were 
asked to come up with three 
measures that their sector could 
take to contribute to the 
achievement of the top 5 success 
factors. 

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The brainstorming took place in the 
breakout groups. Each group appointed a 
“salesperson” as a rapporteur. The 
salespersons were asked to present the 
group’s initial ideas to another breakout 
group and then go back to the original 
group to refine their ideas. Finally, all three 
groups presented their three measures to 
the plenary.  

Plenary discussion – proposed measures 

Civil society organisations (rapporteur: Felix Carvalho from Eurotox):  

1)  Provide recognition of the good work by companies – reward and promote the 
work of sustainable companies that use non-animal methods, environmentally-
friendly processes or that provide excellent working conditions. Companies would 
be invited to propose themselves for the award, and make their own case. 
2)  Disseminate information on chemicals to the audiences with whom they most 
connect. For example, by analysing and digesting data on chemicals and 
presenting their findings to groups like consumers, researchers, innovators etc.  

3)  Cooperate with enforcement authorities and provide consumer product tests. 

There would be a cooperative approach between industry, NGOs and enforcement 
authorities in carrying out the tests. 

 In the following discussion, it was noted that: 

•  ECHA should make more use of its data in identifying and promoting examples of 

best practice to inspire companies and give them benchmarks to aim for. 

•  Downloadable data would enable far more organisations to analyse and make use 

of it – notably academia. 

•  Many member states and consumer organisations already conduct consumer tests 

and so an additional effort by civil society would need to find its own niche. 

Industry group 1 (rapporteur: Francesca Angiulli from AISE): 

1)  Industry must promote and use the tools that are already there to support 

communication in the supply chain. Organisations must also continue the work on 
CSR/ES1 roadmap. Practical tools are what companies need. 

2)  A platform is needed to discuss and exchange lessons learned and success stories 

to promote sustainable substitution. 

3)  If REACH and CLP data is to be shared and used worldwide, then the data 

provided by industry needs to be credible and reliable. Companies must take 
seriously the demand for robust and high quality data, and continuously update 
their dossiers. 

Industry group 2 (rapporteurs: Divina Gomez from FEICA and Roger Doome from IMA-
Europe): 

1)  Supply chain communication – industry needs to better promote the already 

available tools. Improve data to make it robust and use existing tools. 

1 Chemical safety report / exposure scenario 

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2)  Communicate information on safe use – e.g. the SUMIs for workers – but in an 
easy way. There is an ongoing initiative on QR codes for consumers by IMA-
Europe: products would contain information from the safety data sheets, but in 
an easier format through the QR code that can be scanned with a mobile phone. 

3)  Promote alternatives to animal testing and the OECD guidance. 

In the following discussion, it was noted that: 

•  Tools for supply chain communication have been developed by the ENES2 network 
but need to be better promoted, explained and used. They suggested a webinar 
and the need for them to be translated. 

•  Companies might need more incentives to use the use maps. To provide the 
downstream user perspective, DUCC representatives from different countries 
could participate in ENES meetings and also HelpNet members could be involved 
more.  
It is regrettable that the substitution support portal Subsport was no longer 
funded. The participants discussed whether its use could be improved and 
whether ECHA could play a role in ensuring that it could continue as the only 
online resource of its kind.  

• 

•  The IMA-Europe initiative on QR codes providing simplified safety data sheet 

information for consumers raised a lot of interest among participants. This project 
would start with a pilot case on substances and mixtures first.  

•  ECHA informed about an ongoing project application led by the German 

Environment Agency for a consumer app scanning products to provide 
information on SVHCs in them. Some stakeholders were interested in contributing 
to the project if it gets funding. ECHA will follow up through the stakeholder 
update and inform the stakeholders about the next steps.  

•  Participants also asked ECHA to be more open in its communication about the 

weaknesses of registration data.  

•  Further topics included the ECHA-Japan cooperation agreement that could be 

made available on ECHA’s website.  

Closing and next steps 

Geert Dancet closed the event by highlighting the next steps and giving his personal 
reflections from the day. His slides are at Annex 3. He thanked the participants for the 
lively discussions and the feedback they provided to ECHA’s thinking. The meeting 
document with the revised success factors and measures will be consulted with the 
Member States and ECHA’s Management Board before it will be used for ECHA’s strategic 
planning 2018-2020. 

Communication on the follow-up activities will be channelled through the Stakeholder 
update, which is sent bi-monthly to the accredited stakeholders. As before, ECHA will 
also present the outcomes in the next accredited stakeholder workshop. 

The 2017 workshop will partly focus on ECHA’s 5-year strategic planning and partly on 
topics proposed by stakeholders.  

2 ECHA-stakeholder exchange network on exposure scenarios  

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Annex 1 - List of participants 

First name 

Last name 

Organisation 

1  Francesca 

Angiulli 

International Association for Soaps, 
Detergents and Maintenance Products 
(A.I.S.E.) 

2  Erwin 

Annys 

European Chemical Industry Council (Cefic) 

3  Jan 

Backmann 

4  Tobias 

Bahr 

European Federation of Pharmaceutical 
Industries and Associations (EFPIA) 

European Automobile Manufacturers' 
association (ACEA) 

5  Els 

Bedert 

EuroCommerce 

6  Francois 

Busquet 

European Consensus Platform for 3R 
Alternatives to Animal Experimentation 
(ECOPA) 

7  Felix 

Carvalho 

Federation of European Toxicologists & 
European Societies of Toxicology (EUROTOX) 

8  Barbara 

Cooreman 

9  Leondina 

Della Pietra 

Aerospace and Defence Industries 
Association of Europe (ASD) 

European Fertilizer Manufacturers 
Association (Fertilizers Europe) 

10  Alain 

D’haese 

European Aerosol Federation (FEA) 

11  Roger 

Doome 

European Industrial Minerals Association 
(IMA) 

12  Laura 

Dos Santos Rego 

Cruelty Free International 

13  Dunja 

Drmac 

European Apparel and Textile Organisation 
(Euratex) 

14  Irantzu 

Garmendia 

15  Divina 

Gomez 

16  Celia 

Gryspeirt 

European Association of Chemical 
Distributors (FECC) 

Association of European Adhesives and 
Sealants Manufacturers (FEICA) 

European Industrial Minerals Association 
(IMA) 

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European Construction Industry Federation 
(FIEC) 

European Confederation of Iron and Steel 
Industries (EUROFER) 

European Tyre and Rubber Manufacturers' 
Association (ETRMA) 

The oil companies' European organisation for 
environment, health and safety in refining 
and distribution (Concawe) 

17  Marianne 

Hedberg 

18  Anna Maria 

Kaczmarek 

19  Padmaja 

Kamath 

20  Hannu 

Keranen 

21  Michael 

Leise 

Only Representatives Organisation (ORO) 

22  Sean 

McPike 

23  Pelle 

Moos 

European Federation of Pharmaceutical 
Industries and Associations (EFPIA) 

The European's Consumer Organisation 
(BEUC) 

24  Laia 

Perez Simbor 

European Copper Institute (ECI) 

25  Kirsty 

Reid 

Eurogroup for Animals 

26  Marianne 

Rosborg 

European Trade Association for the 
nonwovens and Related Industries (EDANA) 

27  Roderick 

Rowe 

European Crop Protection Association (ECPA) 

28  Tatiana 

Santos Otero 

European Environmental Bureau (EEB) 

29  Mauro 

Scalia 

European Apparel and Textile Organisation 
(Euratex) 

30  Roberto 

Scazzola 

31  Elisa 

Setien 

32  Egbert 

Stremmelaar 

33  Martha 

Unterasinger 

34  Violaine 

Verougstraete 

International Association for Soaps, 
Detergents and Maintenance Products 
(A.I.S.E.) 

European Association of Chemical 
Distributors (FECC) 

European Committee for Surface Treatment 
(CETS) 

European Association of Craft, Small and 
Medium-sized Enterprises (UEAPME) 

European Association of the Metals Industry 
(Eurometaux) 

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35  Lars 

Vogt 

Toy Industries of Europe (TIE) 

36  Tiiu 

Bräutigam 

European Chemicals Agency (ECHA) 

37  Geert 

Dancet 

European Chemicals Agency (ECHA) 

38  Jack 

De Bruijn 

European Chemicals Agency (ECHA) 

39  Wim 

De Coen 

European Chemicals Agency (ECHA) 

40  Adam 

Elwan 

European Chemicals Agency (ECHA) 

41  Lindsay 

Jackson 

European Chemicals Agency (ECHA) 

42  Jukka 

Malm 

European Chemicals Agency (ECHA) 

43  Christel 

Musset 

European Chemicals Agency (ECHA) 

44  Leena 

Ylä-Mononen 

European Chemicals Agency (ECHA) 

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Annex 2 - Agenda 

Accredited Stakeholder Workshop agenda 

Time   

Friday 21 October 2016 

Place   

MCE Conference and Business Centre 

Rue de l'Aqueduc, 118 / Waterleidingsstraat 118  
1050 Ixelles / Elsene, Belgium 

09:00 

Registration and coffee 

09:30 

10:00 

Opening and follow-up on last year’s recommendations, Jukka Malm, 
Deputy Executive Director of ECHA 

What are the success factors that we need to achieve in order to reach the 
World Summit Sustainable Development goals on chemicals? Interactive 
discussions on the success factors and measures we need to take in order 
to get there. 

12:30    

Lunch 

13:30 

Discussions in sector-based break-out groups (one civil society and four 
industry groups) about the measures that stakeholders will or should take 
to contribute to the success factors 

15:10 

        Reporting back from the break-out groups 

16:00    

Conclusions and closing remarks, Geert Dancet, Executive Director of 
ECHA 

16.30 

End 

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Annex 3 - Presentations 

Click on the image to open the full presentation.  

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Annex 4 - Feedback Summary 

This is the summary of the feedback that participants provided to ECHA after the event. 
Altogether 11 participants gave feedback. 

1.  Overall satisfaction 

2.  Breakout groups 

Group discussion morning

Results morning

Group discussion afternoon

Results afternoon

0%

20%

40%

60%

80%

100%

Very good

Good

Satisfactory

Adequate

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3.  Positive feedback 

•  Thanks a lot for the energy invested in this event to achieve dynamic settings, 

allowing people to exchange and reflect. Very nice day overall! 

•  The workshop was effectively interactive. 
•  Coming from a specialised sector we are very encouraged by the openness and 

• 

willingness of ECHA to work with us. If only Efsa could learn from your example! 
I liked the contact/discussions with the group(s) and I think an interactive event 
like this helps to bring the best. 

•  Staff is open to meet and discuss with stakeholders which is very positive. It is 

• 

good you keep it high level with the presence of different directors.  
It is my first ASO workshop and I am positively surprised that ECHA's staff is 
friendly, open to dialogue, listen to the problems of its stakeholders. 

4.  Room for improvement 

• 

If possible, a better mix of different stakeholders is preferable: not too many 
NGOs participated, otherwise it would have been a more vivid discussion in the 
groups.  

•  The afternoon session was probably too short to allow a real discussion but it was 

• 

a good starting point. 
For the afternoon session I would have preferred to have the full range of 
objectives again as a starting point, as the focus was now on industry measures; 
hence the 'top 5' might have been different from the perspective of what industry 
can do. 

•  The discussions were too much connected to the 20 issues. The real world is not 

the ideal world. So more realism is a must. 

5.  Feedback on content 

•  The success factors were well documented and cover the range of activities for 

ECHA, however the measures seem to be confusing and not always appropriate to 
any success factor. Where did they come from? 

•  For some organizations it was challenging to relate to registration, authorization, 

animal testing because it simply didn't relate to them 

•  Many measures and success factors were simply not relevant - therefore, for next 
time it would be good to divide based on upstream/downstream users rather than 
randomly pick a group. 
I got the impression that more commitment on explicit measures was expected 
from stakeholders. This is rather difficult. 

• 

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Annex 5 – Draft meeting document on success factors and measures 

What will success look like in meeting the WSSD 2020 goals?  

The  overall  goal  from  the  world  summit  on  sustainable  development  (WSSD)  is  to  achieve  the  sound  management  of  chemicals 
throughout their lifecycle. The aim is that by 2020, chemicals are used and produced in ways that lead to the minimisation of significant 
adverse effects on human health and the environment. In the EU, the REACH Regulation and the CLP Regulation are the main tools for 
implementing  the  goal.  This  document  describes  what  success  will  look  like  in  meeting  the  2020  goal,  and  the  measures  needed  to 
achieve that.  

Success factors: 

1)  Robust data is available on all chemicals in Europe  

a)  All  chemicals  critical  for  the  supply  chain  in  Europe  are  registered  and  the  2018  deadline  is  successfully  managed  without 

significant market disruption.  

b)  Companies  see  the  data  on  their  chemicals  as  their  business  card  and  are  committed  to  regularly  updating  their  registration 

dossiers with new relevant information. 

c)  Registration data cover the hazards and uses of substances adequately, also for the nanoform. This allows them to be adequately 

classified, labelled and used safely and enables the identification of those which need to be managed through regulation.  

d)  New hazard data is generated using non-animal testing methods and new approaches wherever possible. 
e)  All substances produced in large volumes (over 100 tonnes per year) have been reviewed, and ECHA has concluded, preferably in 

co-operation with the relevant (sub)sectors, which: 

i.  Are of concern; 
ii.  Are currently not of concern; or  
iii.  Need more data for a judgement to be made. 

f)  A  plan  is  in  place  to  identify  candidates  for  further  evaluation  and/or  risk  reduction  amongst  the  lower  volume  substances  

(1-100 tonnes per year).  

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2)  Effective regulatory risk management of the most dangerous chemicals takes place 

g)  Substances of concern are identified and subjected to the most appropriate regulatory risk management measure to protect health 

or the environment, either under REACH and CLP or other legislation. 

h)  The processes for authorisation, restrictions, and harmonised classification and labelling are fully optimised and operate based on 
fit-for-purpose dossiers that allow efficient opinion-forming in the committees and swift decision-making by the Commission. 

3)  Effective communication takes place about the safe use of chemicals up and down the supply chain  

i)  Information about substances flows smoothly and effectively up and down the supply chain. Companies that use chemicals inform 
their suppliers about what they do, and in return, manufacturers and importers provide information on how to use them safely.    

4)  A step-change for citizens, businesses and the regulators takes place  

j)  Information on chemicals is made freely available, to allow individuals, businesses and regulators to make informed choices and to 

increase their confidence in the safety of chemicals – not just in Europe, but around the world.  

k)  The experience of REACH and CLP, the information, methods and tools developed are increasingly used worldwide. 
l)  Companies experience firm and fair enforcement, focussing on ensuring the safe use of hazardous chemicals and fostering a level 

playing field.  

Measures: 

Measures for implementation – robust data 

1.    ECHA together with its partners and stakeholders ensures that all actions identified in the 2018 roadmap are carried out according to 

plan. 

2. 

3. 

 ECHA will have concluded, by the end of 2020, at least a further 800 compliance checks on the priority endpoints of the priority 
substances in the 100-1000 and >1000 tonnes tonnage bands. 

 In parallel, by the end of 2020, Member State competent authorities (MSCAs) evaluate over 400 priority substances under substance 
evaluation and ECHA requests necessary data to conclude on suspected risk. MSCAs conclude the evaluations as soon as the 
necessary data is available and initiate further measures, where relevant.  

4. 

 Targeted campaigns and other complementary measures from ECHA and Member States as well as voluntary actions from industry 

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are carried out to increase the overall quality of all registration dossiers with a measurable impact. 

5.  4 ECHA adapts the registration and data sharing processes to prevent submission of low quality dossiers and to prevent the use of 

these processes for other purposes than they were intended for (e.g. distortion of market). 

6. 

7. 

 ECHA increases transparency of compliance check outcomes by completing the tasks under dissemination (i.e. life-cycle of decision 
making is online, and we have an efficient traceability system in place to be able to report detailed statistics). 

 ECHA has screened with IT-tools the substances with registrations only in 1-10 tonnes and 10-100 tonnes tonnage bands. A plan is in 
place for compliance check or substance evaluation for years 2020-2025 and to support the decision whether priority should continue 
to be assigned to >100 tonnes dossiers. 

8. 

 Registrants implement the revised information requirements for nanomaterials, and ECHA reinforces them via updated guidance and 
advice, and via compliance checks and/or complimentary measures. 

9.  8 Registrants document their considerations on alternative methods and approaches with adequate justifications before proposing new 

animal tests in their registration dossiers. 

10. 9 To further reduce the need for animal testing ECHA promotes the use of new alternative methods and approaches developed in the 
EU and internationally via guidance, advice, awareness raising and training. Where relevant, the Commission is updating the 
information requirements without undue delay. 

Measures for implementation – risk management 

11. 

For substances where the need for regulatory risk management measures is warranted or already identified (e.g. via risk 
management option analysis), ECHA communicates the conclusions to MSCAs and the Commission in an effective manner (mainly 
through the SVHC roadmap coordination activities and risk management expert meetings). Resulting proposals for CLH, SVHC, 
authorisation or restriction are developed within a reasonable timeframe. 

12. 

Substitution is effectively promoted by having all relevant currently known Substances of Very High Concern (SVHCs) included in the 
candidate list by 2020. Substances on the candidate list are regularly prioritised and recommended for inclusion into the 
Authorisation list. 

13. 

The recommendations from both the restriction efficiency and applications for authorisation task forces are fully implemented. 

14. 

Authorities create a framework to communicate on the need for risk reduction measures under other legislation. 

4 

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Measures for implementation – supply chain 

15.   ECHA, Member States, and industry associations keep supporting registrants and downstream users to adopt the methods, tools and 
standardised formats (such as use maps) developed under the chemical safety assessment roadmap. Registrants and companies 
further in the supply chain use these tools widely. 

16.   ECHA continues to promote the communication and sharing of information among industry and between industry and authorities on 

the effective implementation of exposure scenarios as a novel communication vehicle that also serves different EU environmental and 
health legislation. 

Measures for implementation – step-change 

17.   ECHA acts as a data hub for safety information on chemicals and further expands this central data management and dissemination 

role by exploring integration and synergies with other EU legislation in the period post 2018. 

18.   ECHA and Member States promote the development and use of common and harmonised methodologies and tools at OECD and other 

international fora. 

19.   Member States and ECHA agree on effective coordinated enforcement projects to address the issues critical to ensuring a level 

playing field and safe use of substances and all MS’s participate in these projects. 

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Annex 6 – 2015 recommendations follow-up 

Efficiency - what does ECHA need to do to improve on the value rated lowest by stakeholders? 

Recommendation 
from 
stakeholders 

Improve 
consistency and 
predictability  

Actions for ECHA  

Follow-up by ECHA 

Integrate the data sets on chemicals provided 
by the different pieces of legislation  

Provide more stability of Guidance and IT tools 
– notably through the “moratorium” in 2016 

ECHA launched the new, more user-friendly search for chemicals on its 
website in January 2016. More is planned in the near future for integrating 
Biocides information.  

ECHA has set a moratorium for guidance in mid-2016 and informed 
stakeholders about it. Some guidance updates will still be published during 
the second half of 2016. However, they are already available in draft 
format on ECHA website if they are relevant to registration. Stakeholders 
have been informed thereof. 

Provide advance notice of things that will affect 
stakeholders – e.g. IT changes, guidance, 
regulatory changes, alternative test methods  

ECHA’s stakeholder update bulletin has given pre-notice to stakeholders 
on such issues. In addition, several news items have been published on 
upcoming changes.  

Inform companies about delays and explaining 
the reason for them 

To improve the transparency on dossiers, ECHA is planning new web 
pages in 2017, providing more information about the different stages in 
dossier evaluation. 

Provide more consistency and clarity about 
enforcement measures and the use of limit 
figures like OEL / DNELs. 
Communicate also about positive cases and 
developments  

Improve 
communication and 
support  

The Commission has published guidelines related to the use of limit figures 
like OEL / DNELs. 

ECHA’s newsletter regularly showcases positive case studies from 
companies. ECHA staff has been visiting SMEs to learn more about their 
situation and to collect further case studies. New cases about REACH 
benefits have been published on ECHA’s Chemicals in our life web pages 
and new substitution cases have been added to the ECHA website. 

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Enable companies to see what a good example 
looks like (for example, a read-across argument 
or a justification for a proposal to test on 
animals) 

Improve the communication from ECHA by 
reducing the number of current vehicles 

Improve the navigability of the website 

Provide a coordinated calendar with the 
European Commission to prevent clashing 
meetings 

Provide support on read-across 

A new illustrative example for the QSAR Toolbox has been published: 
https://echa.europa.eu/support/oecd-qsar-toolbox 

The new practical guide on alternatives to animal testing contains practical 
advice: https://echa.europa.eu/practical-guides 

A webinar on alternatives to animal testing (22 September 2016) provides 
practical examples. 

In 2017, ECHA will publish case studies as advice to SME managers, as a 
follow-up of the publication of the practical guide for SME managers: 
https://echa.europa.eu/practical-guides 

The new manual How to prepare registration and PPORD dossier also 
contains examples: https://echa.europa.eu/manuals 

ECHA has been streamlining its news vehicles and discontinued the direct 
e-mailing to downstream users. ECHA is planning to create a subscription 
feature on its website in 2017 that allows users to subscribe to different 
kinds of news, according to their specific interests. 

A usability study for the website was conducted in 2015 and first 
improvements are made in 2016 with more substantial changes planned 
for 2017. 

ECHA and Commission colleagues have discussed this and an external 
calendar was not yet feasible. However, the internal coordination of events 
will be further improved. ECHA’s “open-for-all” events will be published in 
the EU newsroom calendar (http://europa.eu/newsroom/events/year_en) 
together with other EU events as of Q4 2016. 

The read-across assessment framework (RAAF) for human health 
endpoints was published in 2015. ECHA plans to complement it with RAAF 
for environmental endpoints in early 2017. A working paper on nanoforms 
and read-across was published in March 2016.  

Respond to comments from public consultations  Currently not planned due to work load.    

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Engage with the providers of safer alternatives 
to SVHCs 

Substitution project ongoing with ASOs, new cases have been added to 
website and newsletter. ECHA commissioned a study on recommendations 
for enhancing substitution activities from the University of Massachusetts 
Lowell. The recommendations are currently being assessed by ECHA. 

Alternatives to animal testing – what more needs to be done to avoid unnecessary animal testing?  

Recommendation 
from 
stakeholders 

Provide more 
information on 
alternatives 

Target consultants 
and inform them 
about alternatives.  

Make sure that 
ECHA’s staff is up-

Actions for ECHA 

Follow-up by ECHA 

List endpoints and alternatives with links in a 
consolidated table  

 An overview table is in the planning for late 2016/early 2017.  

Provide information in practical guides and 
practical examples 

A new practical guide on how to use alternative methods to animal testing 
was published in July 2016: https://echa.europa.eu/practical-guides 

A webinar on alternatives to animal testing (22 September 2016) provides 
practical examples. ECHA also contributed to Chemical Watch’s webinar on 
alternatives. New webpages about alternatives to animal testing were 
published in July 2016, together with the launching of Phase 4 of the ECHA 
2018 Roadmap: https://echa.europa.eu/support/registration/how-to-avoid-
unnecessary-testing-on-animals 

An overview infographic on ECHA’s actions to promote alternatives was 
published in the newsletter 1/2016.   

Publish more infographics to enable newcomers 
to understand how best to avoid testing on 
animals 

Provide them with checklists  

The practical guide for SME managers provides tips for consultants.  

Capacity-building and training 

Ongoing activity.  

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to-date and 
receives training 
about alternatives 

Reaching the REACH goals. Food for thought for ECHA’s report on REACH and CLP implementation.  

Recommendation 
from 
stakeholders 

Actions for ECHA 

Follow-up by ECHA 

Improve synergy 
between the 
regulations  

For example, the EU could be making more use 
of data generated for REACH also to facilitate 
other protective legislation. 

In the report, ECHA recommends that the interface between REACH and 
CLP and other pieces of legislation should be optimised – for example, by 
making more use of the data generated to comply with other EU legislation.   

Provide examples 
of benefits of 
REACH and 
consider how these 
are measured  

Better enforcement 
for substances in 
imported articles;  
Clarify the role of 
REACH in 
sustainable 
economy 

The report contains several testimonials on REACH benefits. A further report 
by ECHA on restrictions calculated the benefits gained so far.  

Stakeholder update used several times to collect further REACH benefits 
from stakeholders. 

New cases for ECHA’s substitution pages published. 

Among the reports’ recommendations, ECHA states that the current 
legislative requirements for substances in articles should be reviewed. This 
could form part of the work on the circular economy and drive towards a 
non-toxic environment.  

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