Commentary on the Löfstedt substitution paper

Julie Girling

Journal of Risk Research, 2014, vol. 17, issue 5, 593-595

Abstract: As noted by Professor Löfstedt in his paper, the substitution of chemicals with safer alternatives forms the core of the EU's flagship REACH Regulation. However, it is important to acknowledge that the principle of substitution is not something new dreamt up by Brussels bureaucrats, but rather reflects existing business practice. Therefore, one would think that this is an issue that both business and regulators can agree on. Of course, in practice the reality is much more nuanced. Substitution can only be effective provided certain conditions are met and that the process is based on sound science and a full risk assessment. By rushing substitution without thinking through the consequences, regulators can risk the process being at best ineffective, and at worst causing significant harm to human health and the environment.

Date: 2014
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DOI: 10.1080/13669877.2013.875937

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