September 9, 2010 by David Taylor


The process of substitution is a core part of the EU REACH Regulation. Anyone applying for authorisation to use a “substance of very high concern” (svhc) that has been added to the list of substances in Annex XIV, must supply a substitution plan along with the application. This plan must detail the efforts made by the applicant to identify an alternative substance that can be used in place of the one on Annex XIV. The plan should indicate the length of time that authorisation is required in order to make the change, or justify why a change is not possible.

Although substitution is, in principle, a simple concept the practical application is more complex. The UK Chemicals Stakeholder Forum has just published a new “Guide to Substitution” which provides a short, readable introduction to the key principles.