Mind the Gap: Interface Problems between EC Chemicals Law and Sectoral Environmental Legislation

Amidst the debate on risks to human beings and the environment resulting from chemicals being used on an increasingly large scale, the European Community's proposed Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Regulation presents a new approach. However, under this new legislation it cannot be guaranteed that all problems that have been experienced under the existing EC chemicals legislation will be addressed satisfactorily. One of the problematic aspects is the question of how chemicals legislation, on the one hand, and sectoral environmental legislation, on the other hand (i.e. specific legislation referring to specific environmental media such as water, air, soil, etc.), complement one another. This article outlines these interface problems against the background of existing legislation and REACH.