Summary: This is an EDA programme that looks at the impact on Defence of the EU’s Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) legislation. It has led to a EDA Code of Conduct (CoC) on REACH Defence Exemptions; a Technical Framework for applying it; a study on the impact of EU chemical regulations on the Defence sector; a Common Position on Ammunition Classification under REACH; and a REACH Roadmap.
At stake: This programme is a prominent reminder of the second order risks on Defence arising from EU regulation.
What they say: “REACH (and associated CLP) regulation, as they stand now, may impact the actual operability of Member States’ Armed Forces” – EDA activity description
Exposure: Depends on the future terms of association. The more UK defence cooperation is run through the EU, the greater the risk of being caught by overregulation.
Action: The UK must ensure that any cooperation with the EU avoids any risk of forced compliance with EU regulations which may have been drafted without considering the special requirements of the Defence sector; it is telling that Governments had to work together with an EU Agency to lobby to disapply rules.
Deep dive: https://www.eda.europa.eu/docs/default-source/documents/eda-reach-study-final-report-2016-december-16-p.pdf