To build a common understanding of the REACH regulatory provisions and facilitate the exchange of best practices in the field of Ammunition Classification, EDA Member States adopted on 22 September a Common Position on Ammunition Classification under REACH.
The Common Position is based on the outcome of the Agency’s work conducted in this field since 2014, with the support of Member States’ REACH and ammunition experts at technical level, and on the basis of a continuous exchange with the European Commission, the European Chemicals Agency and EU defence industry.
The adoption of the Common Position constitutes an important milestone as it will significantly contribute to:
- reducing the risk of misinterpretation of, and enhancing compliance to, the REACH Regulation´s provisions on substances/mixtures or articles;
- supporting the European Defence Technological and Industrial Base (EDTIB) in its efforts to raise awareness on issues pertaining to ammunition classification under REACH; and
- minimising the possibility of potential incorrect classification of ammunition along the REACH Regulation´s provisions on substances/mixtures or articles, and related potential negative impact on the operational effectiveness of Member States’ Armed Forces.
The Common Position reflects EDA participating Member States’ (pMS) position/views on the classification of ammunition categories and types under REACH. It also states that ”Views reflected are for reference only and are not in any way legally binding for those obligated by REACH, the Member States, or other REACH stakeholders. Usage of the information contained in the document remains under the sole responsibility of the users, including ensuring that any conclusions drawn on the basis of the information are compliant with REACH or any other applicable national and EU legislation. The EDA and its pMS adopting this document, will not be held liable or bear any responsibility in this regard.”
The EDA has disseminated the Common Position as widely as possible to relevant stakeholders, including the Commission, ECHA and EU defence industry, and intends to assess potential feedback/comments, as basis for future improvement of the document.