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Response from the BUAV to the REACH Review


The European Commission has today published the long anticipated ‘Review of REACH’; which was to be a comprehensive assessment as to how REACH has worked in the EU since it began in 2007. REACH, the EU chemical testing regime, stands for Registration, Evaluation and Authorisation of Chemicals.

The ECEAE, for which the BUAV is Secretariat, has been the leading animal protection organisation monitoring the implementation of the REACH legislation. We have been pleased to be a key stakeholder in the process, actively commenting on proposals to test on animals and observing, wherever possible, the decisions on these made by the Agency, ECHA. Since the start of it operations in 2008, the Agency has sought to be reasonably open to stakeholders and we have seen recent further improvements in the access to information arising from the work of the Agency. 

However, the ECEAE has experienced many problems related to animal testing and we are disappointed to see that the Commission’s REACH review appears not to have gone far enough to acknowledge these issues. 

One of the central goals of the legislation is the promotion of alternative methods with the requirement that animal testing would be a last resort. The Agency, the Commission and the Member States have however, failed, in our opinion, to uphold these principles. After all the promise of an ‘intelligent’, science-based approach, the Agency has reverted back to conservative, tick-box toxicology. We are seeing routine additional requests for animal tests in some areas, an almost complete failure to reject proposals to test on animals and a lack of leadership from the Commission or the Agency on the promotion of alternative methods that already exist.

In response to the Commission’s Review, the ECEAE has listed its own findings on the Implementation of REACH. The ECEAE findings are:


1. On the Agency responsible for the operation of REACH, ECHA:


2. On the European Commission:


3. On Member States:



4. On the Industry: