An initial iteration or ‘scoping’ SEA should be undertaken relatively quickly (e.g. 1-3 months work), focusing primarily on the authorisation applicant and their likely response to a refused authorisation application and the associated impacts. The practical objectives should be to:
- Narrow the scope of the analysis through understanding the suitability of possible alternatives and whether the market characteristics allow for importing articles/finished products into the EU (e.g. does production need to be near customers?).
- Understand how the applicant is most likely to respond to a refused authorisation and establish the implications of that response. This may also be influenced by how other EU producers and downstream users are expected to react.
- Determine the most likely significant impacts and use readily available data to quantify these impacts to the extent that is possible.
- Identify gaps/weaknesses in the data and analysis and consider the relative merits that improved analysis would add to the conclusions that can be made.
Key messages for an SEA.
- For it to be effectively communicated across different audiences the SEA needs to be understandable to non-economists and well as those without a chemicals risk assessment or industry background
- The SEA should begin by explicitly stating why it is being submitted and what it demonstrates; i.e. that society will be better off by allowing an authorisation of the substance for the specified use.
- The SEA should clearly explain why the substance is being used – in terms of its desirable characteristics – relative to possible alternatives.
- There needs to be an overview of the EU market structure relevant to the use of the substance at an early stage of the SEA report.
- All statements should be properly validated and assumptions of ‘common knowledge’ should be avoided.