SEA and AoA: Two Key Elements in Decision-Making under REACH and BPR

In European chemicals legislation, many of the most delicate decisions—such as granting or refusing an authorisation, or prohibiting the use of a hazardous substance—are not based solely on science. Other factors also come into play, including the economic impact, the technical feasibility of alternatives, and the balance between risks and benefits.

This is where two key tools of the REACH Authorisation process and the Biocidal Products Regulation (BPR) become crucial: the Socio-Economic Analysis (SEA) and the Analysis of Alternatives (AoA).

What is a SEA (Socio-Economic Analysis)?

A Socio-Economic Analysis is an evaluation that weighs the benefits and costs of a regulatory action. It is applied both in authorisation and restriction processes under the REACH Regulation, as well as in important decision-making under the BPR.

For example, when a company applies for authorisation to continue using a substance listed in Annex XIV, it must submit a SEA to demonstrate that the benefits of the use (economic, social, or technical) outweigh the risks. SEA is also used by ECHA and the European Commission during the evaluation stage to assess the economic impact of chemical use and to decide whether it should continue to be permitted.

This analysis is reviewed by ECHA’s Committee for Socio-Economic Analysis (SEAC), whose opinion carries significant weight in the final decision.

What is an AoA (Analysis of Alternatives)?

An Analysis of Alternatives is the document that assesses whether there are other substances or technologies that are less hazardous and could replace the substance in question.

Companies applying for a REACH authorisation must submit an AoA that includes:

  • Whether there are alternative substances that are technically and economically feasible.
  • Any barriers (if they exist) to adopting these alternatives.
  • A comparison of the risks between the current substance and potential substitutes.

If the analysis concludes that suitable alternatives are available, a substitution plan must also be presented, including concrete measures and timelines for implementation. This requirement is even more critical when the substance is identified as a candidate for substitution under the BPR, where the AoA is decisive.

Why are these analyses so important?

Both the SEA and the AoA are essential tools to demonstrate a company’s commitment to safety, sustainability and innovation. They allow companies to:

  • Provide context beyond toxicological risk: employment, costs, broader environmental impact…
  • Facilitate more balanced decision-making by authorities.
  • Prepare for future restrictions or regulatory changes.
  • Increase the chances of success in an authorisation procedure.

In fact, a well-prepared SEA can tip the balance in favour of the applicant, even when the risk is not fully controlled, while a robust AoA positions the company as proactive in substitution strategies.

Who should prepare a SEA or an AoA?

These analyses may be submitted by:

  • An individual company, as part of its REACH authorisation application.
  • A group of companies (in joint applications).
  • ECHA or a Member State, as part of a restriction proposal.

In all cases, the content must be rigorous, well-documented, and consistent with ECHA guidance.

Need help preparing a SEA or AoA?

At ServiREACH, we work with companies facing strategic decisions in their regulatory processes. We help you to:

  • Identify whether you need a SEA or an AoA.
  • Assess the availability of alternatives and their technical implications.
  • Quantify the economic and social impact of continuing to use a substance.
  • Draft solid reports aligned with ECHA and European Commission.

 


 

Contact us and tell us about your case. We can help you build a robust, future-oriented strategy fully aligned with EU chemicals legislation.