REACH

Working to keep animals out of REACH

In June 2007 the new European chemical testing regime, REACH, came into force. Its purpose is to establish whether an estimated 30,000 chemicals on the market are safe for humans and the environment and to control the use of those judged to present a risk. The ECEAE agrees entirely that chemicals should be safe, but disagrees the way to test is on animals.

Assessing safety for each chemical may mean the generation of new safety data, which is predicted to lead to millions of new animal tests. The latest estimate is that approximately 10 million animals may be used as a result of REACH — a staggering number, but much lower than the 45 million originally suggested. This is largely due to key amendments that the ECEAE and other groups helped to secure, where we undertook five years of intense lobbying and campaigning.

We didn't win every battle but we were successful in key areas:

Mandatory sharing of animal data
Manufacturers of chemicals will be required to jointly submit dossiers containing data on the safety of their chemicals. As part of this process, they will be obliged to share any animal data that they already hold — therefore ensuring that animal testing is not duplicated.
Promotion of alternatives
The original REACH proposals mentioned nothing at all about non-animal test methods — but thanks to our extensive lobbying, Article 1 of REACH specifically states that one of its aims is the "promotion of alternative methods for assessments of hazards of substances". It also underlines that the development of alternatives should be prioritized in future EU research.
Public scrutiny period
A key gain was the inclusion of a 45-day scrutiny period for any new animal tests that companies intend to carry out as a result of REACH. Working with our US partners we examined experience gained from the HPV programme in the USA, whereby proposed tests were posted on the internet for public comment, the outcome being that many test proposals could be shown to be avoidable or redesigned to significantly reduce the numbers of animals used. The inclusion of a 45-day scrutiny period within REACH is therefore very significant and has the potential to have a big impact.
Cosmetics
There had been concerns that the new REACH legislation would conflict with the Cosmetics Directive. However, a crucial last-minute amendment was successful which served to specifically exempt cosmetics ingredients from REACH.

What happens next?

The registration phase of REACH will begin in June 2008, initially with substances produced in very high tonnages and, shortly after, those thought to represent a particular risk. Substances produced in the lowest quantity of 1 -10 tonnes per year won't have to be registered until 2018. The first Agency report on the use of non-animal testing strategies is due in 2011 and the Commission's report on funding of alternative test methods is due in 2012.

There is still much that can be done to reduce the impact of REACH upon animals. The ECEAE and its members are key stakeholders in monitoring the effective implementation of this crucial legislation. We are pleased to have developed a constructive working relationship with the new European Chemicals Agency (ECHA) in Helsinki, which has responsibility for the implementation of REACH, as well as competent authorities from across the European member states.

We will continue to work to support and promote the development of new "intelligent" non-animal testing approaches. During the development of REACH we submitted a pioneering report, The Way Forward: a Non-Animal Testing Strategy for Chemicals, which outlined a staged combination of computer, human cell, and test-tube techniques could, taken together, help to substantially reduce the numbers of animals used as REACH unfolds.

The Way Forward: a Non-Animal Testing Strategy
for Chemicals

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REACH

Working to keep animals out of REACH

What happens next?