UK choice: an EU or US system for managing chemical risks?

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Though both the US (TSCA) and EU (REACH) legislation on chemicals share the objective to protect the environment and human health whilst supporting the sector’s competitiveness, they could not be further apart.

REACH has changed risk management governance by requiring companies to demonstrate safety, increase transparency and substitute toxic substances with safer alternatives, whereas TSCA (Toxic Substances Control Act) keeps the burden of proof on public authorities and retains most information as confidential. That is the theory, though in practice the differences are less sharp given that implementation of REACH has been found to be deficient.

Whilst the EU’s regime appears to be less business friendly, with high regulatory costs, litigation expenses are lower and the EU’s chemicals trade surplus has grown by around 5% a year since 2007. The US trade surplus is smaller and declined over the same period.

In this context it is worthwhile looking at China, where chemical production has outpaced both the EU and US. China opted to align with the EU and put in place a China REACH system.

REACH and TSCA description
CEFIC fact & Figures 2018
American Chemistry Council 2018

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