Did you ever wonder how companies can get away with having harmful chemicals on the EU market? Wonder no more.
ChemSec presents to you the ultimate guide to cheat EU chemicals regulation and get away with it. We will show you how to dodge regulation in the first place, and how to delay controls and ensure that your toxic chemical stays on the EU market for a long time once your company has been targeted by the authorities. The steps presented in this guide are all well-tested and proven to work – laggard companies have been following them with great success for years.
Step 1: Don’t reveal your chemical’s true identity
If there’s one thing you should know, it’s that scientific uncertainty stalls the regulatory process. With this in mind, you don’t want anyone to be able to pinpoint your toxic chemical’s composition and identify it. What you want instead is a vague and unclear substance that no one can really put their finger on. So, that’s what you tell them: “Yeah, it’s kind of like this other chemical but at the same time it isn’t, you know, there’s a lot of ‘ifs’ and ‘buts’ to it”.
The European Chemicals Agency (ECHA) will then label it a UVCB substance, which basically means that they don’t know what it is. Alternatively, make sure that your chemical contains contaminants that could – potentially – influence its hazard profile. The important thing is that they can’t know for sure.
Why do you want to do all this? Well, to ensure that regulatory action will be delayed since more information is needed to define and evaluate your chemical properly. Don’t worry, you can always update your registration at a later stage and claim that the substance now is purer, doesn’t have contaminants, or that you now know how to specify its identity.
Step 2: Be smart about the CAS number
Don’t choose a CAS number (chemical identification number) that someone else has already registered and where lots of data is available. That would only increase the risk of ECHA targeting you sooner rather than later. Remember, you want to delay all regulatory action for as long as possible!
Instead, you should use a CAS number that is somewhat descriptive of your chemical but not used by other registrants. If you’re willing to spend 1,000 euros, you could also choose to register a completely new CAS number. This would give you the possibility to tailor it to your every need. How about that for creative freedom?
ChemSec, 24 September 2020