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

2. 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.

3. Lighter, simpler and less costly EU law

4. 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

5. 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 …

6. 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

7. 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

8. 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

9. Tentative timeline Overall Fitness Check:
Finalisation currently expected by April 2018
-> follow up action as necessary (e.g. action plans, legislative proposals)

10. 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

11. Thank you for your attention
Aléxandros Kiriazis
European Commission
DG Environment Unit C.4
1049 Brussels
Belgium