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We, the undersigned, call upon the European Chemicals Agency (ECHA) and the European Union to urgently adopt critical reforms to enhance the safety, independence, and effectiveness of chemical regulations under the REACH Regulation (Registration, Evaluation, Authorisation, and Restriction of Chemicals). These reforms are essential to ensuring that these institutions prioritize public health and environmental protection over industrial and political pressures. We specifically demand the following changes:

1. Strengthen the Application of the Precautionary Principle (Article 1 & Article 68):

• Demand: Amend Article 1 of REACH to explicitly mandate the strict application of the precautionary principle in all decision-making processes. Additionally, modify Article 68 to establish a requirement for precautionary bans on substances where there is scientific uncertainty or potential harm, even before conclusive evidence is available.

• Rationale: The current approach delays action against harmful substances due to the need for conclusive evidence. This change will ensure that potential risks are addressed promptly, protecting public health more effectively.

2. Lower Permissible Exposure Limits for Hazardous Chemicals (Annex XVII & Specific Substances):

• Demand: Amend Annex XVII of REACH to establish significantly lower permissible exposure limits for high-risk chemical categories, including CMRs, endocrine disruptors, and PBT substances. For example:

• Phenoxyethanol: Lower the allowable concentration in cosmetics from 1% to 0.5%, particularly in products intended for infants and children.

• BHT: Reassess the current exposure limits in food and cosmetics, considering recent evidence of endocrine disruption, and reduce allowable concentrations by at least 50%.

• Petrolatum (containing MOSH and MOAH): Implement stricter purification requirements and reduce permissible levels of contaminants to align with the precautionary principle.

• Rationale: These chemicals are allowed at levels that emerging science suggests may not be safe. Lowering permissible exposure limits will better protect vulnerable populations and reduce the risk of long-term health effects.

3. Mandatory Precautionary Labels on Products Under Review (Article 33 & Article 67):

• Demand: Amend Article 33 to require that all products containing substances currently under ECHA review display a precautionary label. This label should clearly state: “This product is under review by ECHA for potential health and environmental risks.” Additionally, Article 67 should include a provision mandating these labels for all restricted substances until their status is fully resolved.

• Rationale: Transparency is crucial for consumer safety. By labeling products under review, consumers are informed about potential risks and can make safer choices while awaiting ECHA’s final decision.

4. Proactive and Automatic Restrictions on Hazardous Chemicals (Article 68):

• Demand: Modify Article 68 to establish an automatic restriction mechanism for substances classified as substances of very high concern (SVHCs) unless they undergo a special authorization process demonstrating that their use is essential and no safer alternatives exist.

• Rationale: This will shift the burden of proof onto industry, ensuring that potentially harmful chemicals are restricted or banned unless they can be proven safe for specific uses, thereby accelerating the removal of dangerous substances from the market.

5. Independent Scientific Reviews and Increased Transparency (Article 54, Article 109 & Article 76):

• Demand: Amend Article 54 to require that at least 70% of studies used in chemical risk assessments are from independent, non-industry-funded sources. Additionally, revise Article 109 to mandate the publication of all data, deliberations, and justifications related to ECHA’s decisions, ensuring full transparency. Article 76 should establish an independent oversight committee composed of experts without ties to the chemical industry, to review and assess ECHA’s actions.

• Rationale: Independent research is crucial for unbiased risk assessments, and transparency allows for public and scientific scrutiny. An independent oversight committee will further ensure that ECHA’s decisions are driven solely by science and public interest.

6. Establish Full Independence of ECHA from the European Commission (Article 75):

• Demand: Revise Article 75 to restructure ECHA as an independent agency, completely detached from the European Commission and other political entities. ECHA should be governed by a board composed of independent scientific experts and funded directly by the EU budget, with safeguards to prevent political or industrial interference.

• Rationale: Current governance ties to the European Commission expose ECHA to potential political pressures that can compromise its impartiality. Full independence is crucial to ensure that ECHA’s decisions are driven solely by scientific evidence and the public good.

7. Legally Binding Deadlines for Substance Evaluations (Article 44):

• Demand: Amend Article 44 to introduce strict, legally binding deadlines for the evaluation of chemical substances, particularly those identified as SVHCs. Evaluations should be completed within 18 months, with extensions granted only under extraordinary circumstances and subject to public disclosure and justification.

• Rationale: The current process can lead to delays in evaluating and restricting harmful chemicals. Binding deadlines will ensure that potentially dangerous substances are dealt with promptly, reducing the risk of prolonged exposure to consumers.

8. Introduction of a Chemical Safety Grading System (New Provision):

• Demand: Introduce a new provision under REACH to establish a chemical safety grading system for consumer products, similar to the Nutri-Score. Products should be graded from A to E based on their chemical safety profile, with mandatory labels on all packaging.

• Rationale: A clear, standardized grading system will provide consumers with accessible information about the safety of the products they use, empowering them to make informed decisions and driving manufacturers to improve product safety.