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Consultations start on authorisation substitution plans


The substitution plans of four applications for authorisation to use a substance of very high concern will open for consultation on 21 October 2020. ECHA’s Committee for Socio-economic Analysis (SEAC) will evaluate the plans and the information received during the consultation to provide scientific underpinning for the European Commission to decide whether or not to grant the authorisations.

Helsinki, 13 October 2020 – The substitution plans of 12 applications need to be evaluated by SEAC following a specific request from the Commission to these applicants. The Commission’s request is a result of a 2019 General Court judgment, which changed the interpretation concerning the suitability of alternatives. Applicants are required to prepare substitution plans and include them in their applications if suitable alternatives are available for their uses in general – although these alternatives might not be technically or economically feasible for the applicant.

The plans of four applications have now sent been sent to ECHA. These concern the use of hexavalent chromium in surface treatments and the curing agent MOCA. The 4-week consultation will take place from 21 October to 18 November 2020. The plans are already published on ECHA’s website.

The substitution plans of the remaining eight applications are expected to arrive by early December and they will be opened for consultation by mid-December. These plans are for uses of the plasticiser DEHP, hexavalent chromium in surface treatments and sodium dichromate in wool dying.

SEAC will evaluate the credibility and completeness of the plans from a scientific viewpoint. It has started working on the first batch of substitution plans and is expected to finalise the assessment by June 2021. The evaluation of the second batch is expected to be completed by September 2021.

The substitution plans will be sent to the Commission, together with SEAC's evaluation, as an addendum to the original opinions. The Commission will then decide whether to grant or refuse the authorisation.

These substitution plans concern applications for which ECHA’s scientific committees had finalised their opinions during 2015-2019.

ECHA has evaluated the substitution plans of new applications submitted more recently and will continue to do so. Additional information and evidence on these plans is collected during the the normal consultations for applications for authorisation, in particular, as part the analysis of alternatives.

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