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declare this application admissible and well-founded;

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annul the contested decision;

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order ECHA to pay the costs of the proceedings.

1.

First plea in law, alleging that the Board of Appeal erred in law when it reviewed the lawfulness of ECHA’s decision TPE-D-2114483466-38-01/F of 4 September 2019 on a testing proposal for the substance Hexahydro-4-methylphthalic anhydride (EC number 243-072-0 and CAS number 19438-60-9) (‘4-MHHPA’);

2.

Second plea in law, alleging that the Board of Appeal erred in law when it concluded that the examination of testing proposals is the same as for the examination of a Compliance Check;

3.

Third plea in law, alleging that the Board of Appeal failed to apply the correct legal test and to consider the Applicant’s arguments, reversed the burden of proof in relation to the requirements of Column 2 of the Section 8.7.3. of the Annex X to the REACH Regulation and failed to address the appellant’s arguments regarding the findings of the WHO Concise International Chemical Assessment Document 75;;

4.

Fourth plea in law, alleging that the Board of Appeal violated/misapplied Articles 91 to 93 of the REACH Regulation;

5.

Fifth plea in law, alleging that the Board of Appeal failed to address the applicant’s pleas in relation to the violation of Article 13 of the TFEU, Article 25 of the REACH Regulation and the principles of protection of animal welfare, proportionality and sound administration.