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Authorisation: continued use of Substances of Very High Concern

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The authorisation process made feasible

The authorisation process is an obligation for companies using substances of very high concern listed on Annex XIV of REACH. The goal of the process is to substitute the use of the substances. Companies are expected to look at alternatives before even considering an application for authorisation. However companies without an alternative can go through the application for authorisation (AfA) process and when granted can continue to use the substance.

The justification for such continued use has many aspects and requires a multi disiplinairy approach. The application needs to document how well the use of the substance is controlled, to what extend alternatives are available, and do the benefits of  the continued use outweigh the risk of the continued use.

From the start Apeiron-Team understood the constraints and difficulties companies have faced with an application for authorisation. Apeiron has developed a structured process for a strong Application for Authorisation. The methodology guides the applicant through the process, explaining the steps ahead, coaching the company internal process, supporting the data collection and most importantly engaging and facilitate the discussion required to develop a sustainable application strategy. Sustainable both in the sense that it supports the goals of the company as being in line with the legal requirements on the continued use of substances of high concern. This requires that we will be present on the shop floor to understand and improve emissions and exposure, we will talk to R&D on their achievements and failures to find alternatives, we will talk to the business to understand the current and future markets of the products and we will talk to executive managers to understand and develop the strategy regarding the current and future use of the substance or their alternatives.

Application of authorisation is not rocket science but it is compiling a consistent and convincing business case why companies and society are better of to continue to use a substance in a controlled way while searching for better.

Current Cases

We support companies in different phases of the authorisation process.

For hydrogenated terphenyls, Apeiron-Team is supporting several companies getting ready in case the substance goes further in the direction of Annex XIV. Currently the substance is proposed for inclusion in the candidate list, but even at this stage it is important for companies using the substance understanding their options and preparing for the future.

For substances already on Annex XIV, Apeiron is working on several applications for authorisations both for individual companies as for groups of companies. Starting early, considering the future options for your use of this substance increases the chance of an optimal outcome.

Apeiron also supports various downstream users in understanding their position after applications have been filed. For instance, regarding the continued use of Cr(VI) Apeiron-Team supports them in making the right choice for an own application of authorisation or and other solution to assure their business continuity.

Relevant Apeiron Services

Apeiron-Team has extensive experience developing applications for authorisation.

REACH authorisation

 

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Posted by
Elke Van Asbroeck
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