Status and purpose of PACT
The Public Activities Coordination Tool (PACT) gives advance notice of the substances that are on an authority's radar for exploring the potential need for regulatory risk management.
PACT lists the substances for which a risk management option analysis (RMOA) or an informal hazard assessment for PBT/vPvB (persistent, bioaccumulative and toxic / very persistent and very bioaccumulative) properties or endocrine disruptor properties is either under development or has been completed since the implementation of the SVHC Roadmap commenced in February 2013. Substances for which a hazard assessment is performed are also discussed informally by the PBT Expert Group or the Endocrine Disruptor Expert Group as appropriate.
Inclusion in the PACT means that a Member State or ECHA is examining the substance, it does not mean that a substance has the suspected properties or that there is need for regulatory risk management actions. The purpose of the hazard assessment is to explore a potential PBT/vPvB or endocrine disruptor concern.
Frequently, the outcome of such an informal assessment is that the substance is considered to not have the hazard properties investigated based on the available information. Similarly, an RMOA aims to clarify whether regulatory risk management is necessary and if yes, which measures would be the most appropriate to initiate.
Even if the outcome of the RMOA is that it would be appropriate to initiate regulatory risk management action, or of a hazard assessment is that a substance is considered to have PBT or endocrine disrupting properties, such outcomes do not have direct legal implications and regulatory relevance as the outcomes presented in PACT are just those of the evaluating authority.
To gain legal and regulatory relevance, the substance assessed needs to successfully pass one or more of the formal risk management and decision-making processes under REACH or CLP, such as harmonised classification and labelling (CLH), SVHC identification/authorisation or restriction.
The intentions to submit a dossier to the mentioned formal processes are notified in the Registry of Intentions.
Early information through PACT gives registrants more time to make sure that their registration data is up to date. Stakeholders will have more time to prepare their contributions to a formal risk management process which potentially will follow the preparatory steps and outcomes indicated in PACT. Anyone else with data on the substance, information on safer alternatives or other material will also have more time to prepare to make their case in the public consultation phase of a potential formal process.