Annex I renewals

The Commission has indicated its surprise at the large amount of data submitted for the first 7 Annex I renewal applications.  This has amounted to as much as a complete dossier being submitted in many cases.  This is obviously a concern as it significantly increases the workload of all concerned.

A draft Regulation for the main phase of the Annex I renewals has been prepared by the Commission and this was discussed at the Standing Committee on 26-27 November.  It is likely that the whole renewal programme will be contained in a single Regulation with appendices to cover the phases of work.

Progress has been made with the allocation of Rapporteurs and there is a possibility that the default position will be for the original RMS to take on the renewal work unless representations have been made by industry to change to another Member State or there are workload issues within a Member State.

There is also discussion as to whether a data call-in system should be implemented in order to guide notifiers and make the submissions smaller in size.