ECHA Updates Criteria for Accredited Stakeholders

Ever wondered what it takes to become an accredited stakeholder in the eyes of ECHA, the European Chemicals Agency, which is the governing body of REACH regulation?

A stakeholder is defined within ECHA as “an individual, group, institution or government with an interest or concern, either economic, societal, or environmental, in a particular measure, proposal or event.”

ECHA´s Management Board just revised the criteria that defines how stakeholder organizations are granted an accreditation with ECHA.  Here are the five eligibility criteria for so-called Accredited Stakeholders, as amended:

Criteria 1 – Established in and for the EU

An entity seeking status as an accredited stakeholder must be legally established within the EU/EEA and have activities at the EU level.  This means that an eligible organisation has to be legally established in one of the EU Member States, Iceland, Liechtenstein or Norway.  EU level activities are activities targeted at an EU-wide audience, i.e. not limited to the local, national or regional level. To prove it, the place of legal establishment may be evidenced by the founding document or any other suitable document proving that the entity’s seat is located in the EU, Iceland, Liechtenstein or Norway. (Organisations can explain the scope of their activities in the application form.)

Criteria 2 – Legitimate interest

The entitiy must have a “legitimate interest” in the areas of work of ECHA. This means that the organisation applying for accredited stakeholdership represents a sector affected by the EU chemicals legislation (such as the REACH, CLP, Biocides or PIC Regulation) falling within the scope of the tasks of ECHA. An organisation is also considered to have a legitimate interest in the areas of work of ECHA if it represents a sector indirectly affected by the legislation; this can also include non-governmental organisations (NGOs) engaged in issues affected by the mentioned legislation.  Typcially, ECHA’s Accredited Stakeholders are active in industry, human health, animal welfare, environmental protection, scientific research and development, and consumer protection.  Organisations are expected to depict their legitimate interest in the application.

Criteria 3 – Representative

The entity must be “representative” in the field of their competence.  This means the organization must represent the interests of a substantial part of the actors in its field of competence.  ECHA’s Accredited Stakeholders should be representative of actors in their sector or field of competence.  The necessary number of member organisations and their size depends on the structure of the relevant sector.  (Note: the sector need not have a particular size, but must be distinguishable from other sectors with different fields of interest.)  Organisations are expected to set out why they can be considered “representative” in the application form.

Criteria 4 – Non-profit

Entities must be “non-profit” and not exclusively represent individual companies.  A non-profit organisation here means one which is not operating for its own commercial profit or gain but conducts its operations for the benefit of its members or of the general public.
Non-profit status may be evidenced by the founding document or any other suitable document and must be provided during the application process.

Criteria 5 – Register

Organization must be registered in the Register of Interest Representatives maintained by the European Commission. This criterion only applies in cases where the organization wishes to participate as an observer in the Committee and Forum meetings of ECHA. There is no charge to register, it’s necessary for tracking the flow of information.

All organizations are requested to indicate their registration number in the application form.

Note:  all accredited stakeholders who wish to attend ECHA Committee and Forum meetings need to sign up in the Transparency Register, which is operated by the European parliament and the European Commission.

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About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.