I agreed to take over the chairmanship of the REACH Authorisation Alliance - initiated by EcoMundo - in 2019, considering it a relevant response to the complexity for a downstream user of a substance to define a strategy towards REACH Authorisation adapted to its interests.
Since then, with the requirement to present a substitution plan in any application for authorisation, it has become even more vital for the sustainability of their production that downstream users get involved in the authorisation applications. Indeed, if they do not take control of the process, they risk having the availability of the substance stopped prematurely either because suppliers do not apply for authorisation or because their application for authorisation is rejected because of a non-credible substitution plan.
The experience of the early implementation of REACH is that, despite the long lead times, particularly in relation to company cycles, the deadlines are confirmed and the constraints remain firm. In other words, the substances in Annex XIV must be substituted and authorisation only allows a period of adaptation.
In my experience, the main risk for industrialists is that, as chemical management is not their core business, they are totally unaware of their risks. And when they do become aware of them, it is very difficult for them to define their priorities, for example because there is a lot of information (number of substances, decision logic, timeframe for taking effect, valid alternatives) and they have to organise their action plans in a rush.
The Alliance intervenes on the one hand to provide its members with synthetic information and reflections to understand the risks and issues and refine their strategy. On the other hand, it provides a forum for dialogue between members with similar issues to identify areas of convergence in terms of risk management for certain substances and, for example, to consider a joint authorisation dossier.
With the support of the EcoMundo team, whose technical and strategic expertise is based on numerous application files, I am convinced that the Alliance will be able to offer its members tailored and intelligent solutions.
The Alliance powered by EcoMundo allows to anticipate regulatory risks on chemical substances.
President of the REACH
Formerly in charge of the REACH programme at Safran, Pascal Frou was particularly interested in the competitiveness lever that the REACH regulation represents in the company's strategy.
He is dedicated to strategic analysis that creates the conditions for a stable and decompartmentalised operation between the businesses and players in the value chain.