5 key lessons for a successful Socio-Economic Analysis when applying for a REACH Authorization
Here we share with you the five key points that emerged from these events and their practical implications in the context of completing an Authorization Request. As an indication, we put them into perspective with the methodology applied by EcoMundo experts.
1. Alternative Analysis is at the heart of Socio-Economic Analysis
Alternative Analysis (AoA) plays a central role in carrying out Socio-Economic Analysis (SEA) for REACH Authorization applications: it aims to demonstrate the non-feasibility of alternatives and then to define the “non-use” scenario.
In this context, particular attention should be paid to:
- On thecomprehensiveness of the description of alternative processes, based on the four criteria defining the unavailability of a potential alternative: technical feasibility, economic feasibility, availability and level of risk for humans and the environment.
- On theArticulation of the demonstration of the non-use scenario with the content of the Alternative Analysis. The latter is a key element of Socio-Economic Analysis and derives in part from the substitution strategy that is being considered; it must therefore be both realistic and reasoned.
What about the EcoMundo method?
Authorization requests produced by EcoMundo are all based on the “AOA-Sea” aggregated format proposed by ECHA and incorporate direct links between Alternative Analysis and Socio-Economic Analysis. Particular attention is given to the definition of the non-use scenario.
2. Broadening the scope of Socio-Economic Analysis
Socio-Economic Analyses carried out as part of REACH Authorization applications are, logically, focused on the direct impacts for the requesting company: loss of income and profits, impact on employment or loss of investments.
In order to offer a more global vision of the impacts of an Authorization, it is however necessary tobroaden the scope of this analysis to the consequences for the Society as a whole, in particular with regard to the impacts on all actors in the value chain and/or on providers of alternative solutions.
The assessment of impacts that are outside the direct scope of the requesting company is relatively complex, due to the difficulties of collecting data and accurately characterizing the market response to the Authorization situation.
What about the EcoMundo method?
Beyond the direct impacts for the requesting company, EcoMundo integrates a broad scope into its analysis, in particular with regard to impacts on the value chain of the activity concerned. Internal work is underway to further broaden the scope of assessment in order to include a more global vision of the possible compromises for society associated with the authorization request.
3. Authorization is a demanding process whose results are not guaranteed
A recent meta-analysis of the applications submitted to date, conducted by ECHA, highlighted several statistical data about the REACH Authorization process:
- 52% of the submitted files saw the duration of their reduced revision period compared to their original request
- On average, applicants requested a review period of 10.3 years and have received a duration of 7.5 years by the Committees
- The monetary impacts of the non-use scenario are, on average, reduced by around 80% by the committees, compared to the amounts estimated by the applicants (the average impact amount calculated by the applicants is €50 million while the final amount selected by the Committees is around €10 million).
What about the EcoMundo method?
EcoMundo's methods and arguments have been positively received by ECHA Committees: all files submitted since 2015 have received the requested length of review period, for a total of 8 uses.
4. The assessment of impacts on human health and the environment is a central element of an application for authorization.
The presentations and discussions in both seminars demonstrated the criticality ofassessment of impacts on human health and the environment associated with the use of the substances covered by the Authorization.
Methods for quantifying impacts on human health are already widespread but can nevertheless be improved, especially with regard to productivity losses.
The methods of characterization and monetization of environmental risks, on the other hand, are still under development, particularly with regard to the properties of the substances in the 5th and 6th recommendations for inclusion in Annex XIV of REACH.
What about the EcoMundo method?
EcoMundo experts are constantly enriching their technical knowledge, as evidenced by their method for assessing impacts on human health, specifically developed for the REACH Authorization. By participating in expert seminars such as those in Brussels and Helsinki, we are committed to monitoring the state of the art of characterization and monetization techniques.
5. Upstream requests are inherently complex
One of the strong messages of the two seminars concerns complexity inherent to upstream requests, for which a substance supplier submits an application for an Authorization in order to cover its entire downstream chain.
Such requests are both difficult to prepare by the applicants, but also complex to assess by ECHA and would require very significant resources to offer the level of detail expected by ECHA in describing the downstream chain and the costs/benefits associated with the Authorization.
What about the EcoMundo method?
THEsectoral scale (grouping of downstream users of substances) offers very interesting perspectives in the context of authorization applications, insofar as it allowsoptimize resources through the creation of a dedicated consortium while offering a sufficiently homogeneous perimeter to allow a precise description of the value chain concerned.
Do you want to know more about the REACH Authorization processes?
For more information, do not hesitate to contact our experts.
Here we share with you the five key points that emerged from these events and their practical implications in the context of completing an Authorization Request. As an indication, we put them into perspective with the methodology applied by EcoMundo experts.
1. Alternative Analysis is at the heart of Socio-Economic Analysis
Alternative Analysis (AoA) plays a central role in carrying out Socio-Economic Analysis (SEA) for REACH Authorization applications: it aims to demonstrate the non-feasibility of alternatives and then to define the “non-use” scenario.
In this context, particular attention should be paid to:
- On thecomprehensiveness of the description of alternative processes, based on the four criteria defining the unavailability of a potential alternative: technical feasibility, economic feasibility, availability and level of risk for humans and the environment.
- On theArticulation of the demonstration of the non-use scenario with the content of the Alternative Analysis. The latter is a key element of Socio-Economic Analysis and derives in part from the substitution strategy that is being considered; it must therefore be both realistic and reasoned.
What about the EcoMundo method?
Authorization requests produced by EcoMundo are all based on the “AOA-Sea” aggregated format proposed by ECHA and incorporate direct links between Alternative Analysis and Socio-Economic Analysis. Particular attention is given to the definition of the non-use scenario.
2. Broadening the scope of Socio-Economic Analysis
Socio-Economic Analyses carried out as part of REACH Authorization applications are, logically, focused on the direct impacts for the requesting company: loss of income and profits, impact on employment or loss of investments.
In order to offer a more global vision of the impacts of an Authorization, it is however necessary tobroaden the scope of this analysis to the consequences for the Society as a whole, in particular with regard to the impacts on all actors in the value chain and/or on providers of alternative solutions.
The assessment of impacts that are outside the direct scope of the requesting company is relatively complex, due to the difficulties of collecting data and accurately characterizing the market response to the Authorization situation.
What about the EcoMundo method?
Beyond the direct impacts for the requesting company, EcoMundo integrates a broad scope into its analysis, in particular with regard to impacts on the value chain of the activity concerned. Internal work is underway to further broaden the scope of assessment in order to include a more global vision of the possible compromises for society associated with the authorization request.
3. Authorization is a demanding process whose results are not guaranteed
A recent meta-analysis of the applications submitted to date, conducted by ECHA, highlighted several statistical data about the REACH Authorization process:
- 52% of the submitted files saw the duration of their reduced revision period compared to their original request
- On average, applicants requested a review period of 10.3 years and have received a duration of 7.5 years by the Committees
- The monetary impacts of the non-use scenario are, on average, reduced by around 80% by the committees, compared to the amounts estimated by the applicants (the average impact amount calculated by the applicants is €50 million while the final amount selected by the Committees is around €10 million).
What about the EcoMundo method?
EcoMundo's methods and arguments have been positively received by ECHA Committees: all files submitted since 2015 have received the requested length of review period, for a total of 8 uses.
4. The assessment of impacts on human health and the environment is a central element of an application for authorization.
The presentations and discussions in both seminars demonstrated the criticality ofassessment of impacts on human health and the environment associated with the use of the substances covered by the Authorization.
Methods for quantifying impacts on human health are already widespread but can nevertheless be improved, especially with regard to productivity losses.
The methods of characterization and monetization of environmental risks, on the other hand, are still under development, particularly with regard to the properties of the substances in the 5th and 6th recommendations for inclusion in Annex XIV of REACH.
What about the EcoMundo method?
EcoMundo experts are constantly enriching their technical knowledge, as evidenced by their method for assessing impacts on human health, specifically developed for the REACH Authorization. By participating in expert seminars such as those in Brussels and Helsinki, we are committed to monitoring the state of the art of characterization and monetization techniques.
5. Upstream requests are inherently complex
One of the strong messages of the two seminars concerns complexity inherent to upstream requests, for which a substance supplier submits an application for an Authorization in order to cover its entire downstream chain.
Such requests are both difficult to prepare by the applicants, but also complex to assess by ECHA and would require very significant resources to offer the level of detail expected by ECHA in describing the downstream chain and the costs/benefits associated with the Authorization.
What about the EcoMundo method?
THEsectoral scale (grouping of downstream users of substances) offers very interesting perspectives in the context of authorization applications, insofar as it allowsoptimize resources through the creation of a dedicated consortium while offering a sufficiently homogeneous perimeter to allow a precise description of the value chain concerned.
Do you want to know more about the REACH Authorization processes?
For more information, do not hesitate to contact our experts.
