Cefic says EU regulators should stick to a case-by-case approach when considering whether REACH substances cause equivalent concern for the environment.
The recommendation was made in a "reflection paper" supplied to the Competent Authorities for REACH and CLP (Caracal) meeting in November.
The paper addresses identification of substances of very high concern (SVHC) under REACH, a key step in the process of establishing risk management measures.
Substances can be identified as SVCHs because they have certain CLP hazard classifications, such as category 1A or 1B carcinogenicity, mutagenicity or reproductive toxicity (CMR). Alternatively, they can be identified because they give rise to an "equivalent level of concern" (Eloc).
Cefic says that identification of SVCHs for the environment when based on ELOC, in order to protect ground and drinking water, is "premature".
The trade association calls for a policy paper on factors regulators should consider when using this mechanism and criteria for equivalency.
"A paper should be developed and discussed together with stakeholders well before any application in Annex XV dossier proposal," it says.
Germany's Federal Environment Agency (UBA) has proposed use of the Eloc mechanism for identification of persistent, mobile and toxic (PMT) substances as SVHCs. The topic was discussed in April at a two-day workshop run by UBA and the Norwegian Geotechnical Institute (NGI). The aim of the UBA proposal is to protect humans and the environment from some substances that have the potential to circulate very widely in water systems and contaminate, in particular, drinking water.
Echa confirmed at the workshop that it is already possible to use the Eloc mechanism for PMT substances, provided there is sufficient evidence. Industry, however, voiced opposition to the proposal, warning of a rush to regrettable regulation.