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With this EC decision, the "science-based authorisation system" remains intact but will now be just the first stage in the authorisation process.
They said: "This system is configured to record and store information contained in the authorisation and to produce reports on the total number of authorisations.
Although the commission is bound to follow ECHA's guidance, some countries made an explicit reference to this – and a cut in the authorisation period – conditions for their support.
Agriculture minister Brendan Smith explained this week that "it has been a matter of great concern to Ireland, in recent years, that there has been a severe disruption to trade of animal feed, caused by the delays in the authorisation, by the EU, of GM varieties which have already been approved in the exporting countries".
In addition to that, the interface between restrictions and authorisations needs to be improved to include SVHC in (imported) articles in the authorisation regime.
Can entrance criteria be developed in order to identify especially problematic substances for ecotoxicological risk assessment in the authorisation of PPP?
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In contrast, the authorisation requirement is triggered by a hazard potential, including situations where these are to some extent uncertain.
To determine the risks in case the authorisation scheme's goals are not fulfilled, the 'nature of the risks' to human health and the environment caused by SVHC have to be examined [21].
Nevertheless, having regard to the information on the negotiating history which I have been given and to the arguments of the US Administration which I heard in Washington, I accept that a reasonable case can be made that resolution 1441 is capable in principle of reviving the authorisation in 678 without a further resolution.
I judge that, having regard to the arguments on both sides, and considering the resolution as a whole in the light of the statements made on adoption and subsequently, a court might well conclude that OPs 4 and 12 do require a further Council decision in order to revive the authorisation in resolution 678.
At the same time REACH enforcement in 18 EEA countries shows very low numbers regarding non-compliance in reference to the authorisation regime de lege lata (three cases of non-compliances in 421 inspections) [25].
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Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com