With its expertise, DUCC contributes actively to the effective implementation of the REACH and CLP Regulations, aiming to improve the workability of the system.

DUCC has actively contributed during the legal process for the adoption of REACH, making and advocating several concrete proposals, which include:

• Support for a pre-registration step and exposure-driven, tiered risk assessment approach as promoted by ECETOC (Centre for Ecotoxicology and Toxicology of Chemicals) and as illustrated by the HERA (Human and Environmental Risk Assessment) model.
• The necessity to carry out risk assessments ahead of any decisions o­n restriction or authorisation
• Encouraging centralised decisions through the creation of a European Chemicals Agency.
• Proposing mechanisms for involvement of Downstream Users in registration dossiers, particularly o­n exposure assessment

Since the publication of both REACH and CLP, DUCC is advising and helping its members in their implementation activities, through the exchange of knowledge and experience, and through common activities which are organised as and when needed. It also coordinates activities in certain areas of common interest, e.g. downstream users’ generic exposure scenarios.

DUCC also establishes common positions o­n issues related to other chemicals regulations.

DUCC is in a regular dialogue with the European Commission and the European Chemicals Agency (ECHA) to ensure that downstream users’ concerns are appropriately addressed. In this context, DUCC is actively contributing to the implementation activities organised by the European Commission and by ECHA, for example o­n REACH guidance development and update.

DUCC members meet regularly to discuss the issues o­n their common agenda that are relevant in the DUCC context. The group is functioning by consensus and o­nly positions agreed by all DUCC members become DUCC positions and are advocated as such.

DUCC strongly believes in a modern and effective management of chemicals in Europe based o­n the following principles:

• decisions related to control of chemicals' based o­n sound science
• internationally recognised risk assessment concepts
• avoiding duplication or contradiction of legislation in the areas of health, environment and product safety
• good and effective communication flows between producers and users of chemicals
• communication to the public should be risk orientated rather than hazard-based o­nly
• specific needs of small and medium-sized enterprises (SMEs) should be taken into account