Political Economy of Listing of Substances of Very High Concern in the European REACH Regulation

Abstract

The Candidate List of the European Union regulation on the registration, evaluation, authorization, and restriction of chemicals—known as REACH— gives advanced information to industry and other stakeholders about substances that may have serious effects on human health and the environment—known as substances of very high concern (SVHCs). Both the European Chemical Agency and EEA Member States can prepare dossiers proposing substances to be considered for inclusion on the Candidate List. This study investigates what types of SVHCs are suggested by different countries, and in particular, how the national production of the substances and their toxicological properties can affect the countries’ decision to submit a dossier. Moreover, I investigate what substances for which a dossier has been submitted are finally put forward for inclusion on the Candidate List and what types of comments are raised during the public consultation allowing stakeholders to provide further information on the properties of the substance. The results indicate that national economic interests have affected not only the decisions to submit a dossier but also what substances to propose for inclusion on the list, where countries submit dossiers mainly for substances where they expect little opposition from other member countries or from domestic actors.