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Regulatory Toxicology and Pharmacology
journal homepage: www.elsevier.com/locate/yrtph
Impact of REACH legislation on the production and importation of CMR
(carcinogen, mutagen and reproductive) and explosive chemicals in Italy
from 2011 to 2015
Marco Marzo
a,*
, Caterina Leone
a
, Cosimo Toma
a
, Alessandra Roncaglioni
a
, Stefano Gianazzi
b
,
Ralf Knauf
c
, Emilio Benfenati
a
a
Laboratory of Environmental Chemistry and Toxicology, Department of Environmental Health Sciences, IRCCS-Istituto di Ricerche Farmacologiche Mario Negri, Via La
Masa 19, 20156, Milano, Italy
b
Ticass S.c.r.l., Genova, Italy
c
Centro REACH S.r.l., Milano, Italy
ARTICLE INFO
Keywords:
REACH regulation
Carcinogen
Mutagen and reproductive toxicity
Explosivity
Italian chemical market
ABSTRACT
On 1 June 2007, the European Commission issued the Registration, Evaluation, Authorization and Restriction of
Chemicals (REACH) to protect both the environment and human health. We analyzed the impact of REACH in
the Italian market considering the presence of chemicals, their diversity, importation and production during the
period 2011–2015, with particular attention to products with toxic or explosive properties. There was a re-
duction of the chemicals on the market, in terms of tons but also the absolute numbers of types of compounds.
The production reduction was particularly noticeable for explosive chemicals: -14.7%. CMR products did not
show any statistically significant reduction in term of tons: -2.3%.
1. Introduction
On 1 June 2007, the European Commission issued Regulation (EC)
No. 1907/2006 concerning the Registration, Evaluation, Authorization
and Restriction of Chemicals (REACH) with the aim to protect both the
environment and human health and to make European industry in-
novative and more competitive. The REACH Regulation affects not only
the chemical industry as producers but also a large number of others
such as 1) importers of chemicals, mixtures and products; 2) down-
stream users managing or handling chemicals; 3) the overall population
and the environment in general (Understanding REACH, 2018). The
fact that there have long been substances with very limited information
on human health and environmental impact on the European market
led the legislators to develop a strategy to ensure higher levels of safety
and to set out principles that in fact have completely changed the ap-
proach to importation, production and use of chemicals.
One of the basic criteria of REACH is the precautionary principle:
manufacturers and importers of chemicals have to demonstrate that
their substances do not pose any risk to the environment and to human
health before they can be placed on the market (Leinen, 2012). The
REACH Regulation shifted the “burden of proof” from authorities to
companies, which have now to prove the safety in manufacturing and
use of substances and report detailed information on risk management
in their supply chains.
Another key principle is “extended producer responsibility” (EPR).
According to the Organisation for Economic Co-operation and
Development (OECD) definition, EPR is “an environmental policy ap-
proach in which a producer's responsibility for a product is extended to
the post-consumer stage of a product's life cycle”. So manufacturers and
importers have to communicate and report in their registration dossiers
all relevant properties (physico-chemical properties, toxicological
properties, etc.) for the substances they intend to introduce (or in-
troduced before the REACH Regulation came into force) onto the
market in order to ensure that users apply the correct risk management
measures when they manage such chemicals (OECD, 2001). A third
principle is the “authorization and restriction” of dangerous substances,
that guarantees stricter rules in production and importation of sub-
stances of very high concern (SVHC) (Arfaoui et al., 2014).
To achieve a gradual transition the Regulation sets three registra-
tion deadlines for various categories:
(i) substances manufactured or imported at 1000 tons or more per
year; carcinogenic, mutagenic or toxic to reproduction (CMR)
substances above one ton a year; and substances dangerous for
https://doi.org/10.1016/j.yrtph.2018.11.013
Received 15 June 2018; Received in revised form 19 November 2018; Accepted 23 November 2018
*
Corresponding author. IRCCS-Istituto di Ricerche Farmacologiche Mario Negri, Via La Masa 19, 20156 Milano, Italy. Tel.: +39 02 3901 4396.
E-mail address: Marco.marzo@marionegri.it (M. Marzo).
Regulatory Toxicology and Pharmacology 101 (2019) 166–171
Available online 28 November 2018
0273-2300/ © 2018 Elsevier Inc. All rights reserved.
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