REFIT Fitness Check Chemicals Legislation Outcome of the study on CLP and downstream legislation – Seveso III links

What is REFIT? REFIT is the European Commission's Regulatory Fitness and Performance programme to: make EU law simpler reduce regulatory costs, contribute to a clear, stable and predictable regulatory framework support growth and jobs.

Lighter, simpler and less costly EU law

Aim of the fitness check To assess whether the current legislative framework for chemicals (excluding REACH*), is fit for purpose and delivers as intended: assess the overall effectiveness, efficiency, relevance, coherence, and EU added value of this legislative framework and its procedures; identify possible excessive regulatory burdens, overlaps, inconsistencies, obsolete measures and gaps in the legislative framework * A separate process is conducted for REACH

Components of the fitness check Related studies: Regulatory fitness of the legislative framework governing the risk management of chemicals CLP regulation and downstream legislation (incl. Seveso-III, coordinated by DG GROW) Legislation not linked to CLP (coordinated by DG ENV) Cumulative cost assessment of chemicals legislation European Chemical Industry (CCA-I Study) International comparison of cumulative regulatory costs (CCA-II) Environmental & health benefits of chemicals legislation …

Study: CLP & downstream legislation Relations with Seveso-III: Seveso-III one of pieces of legislation that was closer investigated Other include: toys, biocides, plant protection, waste, occupational health and safety … Seveso-III gets mentioned at numerous occasions in the main report and in several case studies Specific Case Study on Seveso-III Linkages between CLP and Seveso-III, including risk management under Seveso III outcome will feed into Seveso-III assessment in 2020

Study: CLP & downstream legislation Selected overall findings: Framework is effective, efficient, relevant, coherent and has EU added value Problems exist in the details, examples are: Harmonisation of CLP implementation could be improved Combined effects of chemicals are not sufficiently taken into account For some hazards (e.g. bioaccumulation, immunotoxicity) gaps and inconsistencies exist It is appropriate to have different risk management approaches in sectorial legislation CLP is considered to be the most appropriate starting point for risk management (in particular for Seveso) Unintended impacts of CLP changes would have to be considered

Study: CLP & downstream legislation Selected Seveso-III related findings: Seveso-III is seen as positive example for risk management Firm (based on CLP) but flexible (case specific risk assessments) Various options exist to accommodate changes in CLP Relatively little criticism by individual stakeholders Seveso would cover substances not capable of causing major accidents Article 4 procedures would be cumbersome and lengthy Synergies with Industrial Emissions Directive could be exploited Only few stakeholders reported falling newly under Seveso-III

Tentative timeline Overall Fitness Check: Finalisation currently expected by April 2018 -> follow up action as necessary (e.g. action plans, legislative proposals) http://ec.europa.eu/growth/sectors/chemicals/ec-support

Summary Work on CLP and downstream legislation is completed Study to be published soon Seveso-III has been assessed positively Outcome will feed into the next Seveso-III implementation report Several studies still ongoing Final results not before 2018

Thank you for your attention Aléxandros Kiriazis European Commission DG Environment Unit C.4 1049 Brussels Belgium env-seveso@ec.europa.eu http://ec.europa.eu/environment/seveso