Common data platform on chemicals, establishing a monitoring and outlook framework for chemicals

AMFEP, the representative association of manufacturers and formulators of enzyme products, welcomes the Commissions ambition to remove legislative obstacles for the re-use of data and better streamline the flow of chemical data between EU and national authorities, in line with the objectives of the Chemicals Strategy for Sustainability.

COSMED, the French Cosmetic Association for SMEs, supports the main objective of the OSOA package. We however would like to draw attention on some key elements (definition, relevance of data, use of NAMs, study notification, confidentiality, access and use of data). Regarding the re-attribution of scientific and technical tasks to the ECHA, the best available expertise should be used.

Swedish Society for Nature Conservation (SSNC) support the Commissions Proposal for a Regulation establishing a common data platform on chemicals, with the aim to provide a high level of protection of human health and the environment from the adverse effects of harmful chemicals under the one substance, one assessment approach.

Eurogroup for Animals, Cruelty Free Europe and the European Coalition to End Animal Experiments welcome the publication of the proposal to establish a common data platform on chemicals data (the proposal), and very much support the objectives, as initially expressed by the Commission, to: improve access to chemicals data by removing technical and administrative obstacles.

AnimalhealthEurope is the EU trade association representing manufacturers and developers of animal medicines, vaccines and other animal health products in Europe. It is essential that any action implemented through these legislations will not impact the availability, quality and supply of safe and efficacious medicines and vaccines for animals both in Europe and worldwide nor to inadvertently hinder innovation.

PETA Science Consortium International e.V. welcomes the opportunity to contribute to the consultation 'Chemical safety better access to chemicals data for safety assessments', which includes the aim of establishing a common data platform for chemicals to ensure data findability, accessibility, interoperability, and reusability of data.

The EU Commission's proposals represent an important building block of the chemicals strategy for sustainability. The chosen approach to 1S1A is fundamentally appropriate and, if successfully implemented, in accordance with the manner outlined in the regulations and in the SWD. It offers the opportunity to improve access to chemicals data and to reduce unnecessary differences between the various regulations.

The Polish Union of the Cosmetics Industry supports the main objectives of the Chemical Strategy for Sustainability (CSS) including OSOA approach - to improve the efficiency, effectiveness, coherence, and transparency of safety assessments of chemicals across different pieces of EU legislation.

Comments from the Norwegian Environment Agency on behalf of the Norwegian authorities to the Commission's proposal for a regulation establishing a common data platform on chemicals We welcome the proposed regulation establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable and establishing a monitoring and outlook…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ChemSec comment on the public consultation of the proposal for a regulation establishing a common data platform on chemicals ChemSec welcomes the Proposal for a Regulation establishing a common data platform on chemicals, which was published by the European Commission on the 7th of December 2023.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

4 April 2024 COMMENTS of the Polish Association of Cosmetic and Detergent Industry on the on the One substance One Assessment legislative package (public consultation’ April 2024) PACDI, the Polish Association of Cosmetic and Detergent Industry, founded in 1992, represents 150 companies - the manufacturers of cosmetic and personal care products as well as broadly defined cleaning products.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Apparel and Textile Confederation (EURATEX) welcomes the opportunity to provide feedback to the Commission's One Substance, One Assessment legislative package. Please find EURATEX's input in the attached document, which highlights our concerns around security of information, notification of studies, and tasks for the European Chemicals Agency (ECHA).

The Downstream User of Chemicals Coordination Group (DUCC), representing 11 European associations whose member companies use chemicals to formulate mixtures, provides the following response to the OSOA public consultation.

The International Fragrance Association (IFRA) would like to express its support to the main objective of the One Substance, One Assessment approach (OSOA) under the Chemicals Strategy for Sustainability (CSS) to improve the efficiency, effectiveness, coherence, and transparency of chemical safety assessments across different pieces of EU legislation.

AESGP, the Association of the European Self-Care Industry, is a non-profit organisation that represents the manufacturers of non-prescription medicines, food supplements, and self-care medical devices in Europe, an area also referred to as self-care or consumer healthcare products, takes the opportunity to share its views on the One Substance, One Assessment (OSOA) package of legislative proposals published on 7…

The European Partnership for the Assessment of Risks from Chemicals (PARC), a public-public European partnership initiated in 2022, is a collaborative effort involving over 200 organisations working in the areas of the environment or public health from 29 countries, co-funded under the EU's Horizon Europe framework. PARC's mission is to advance chemical risk assessment to safeguard human health and the environment.

APRIL 2024 Proposal for an EU Regulation establishing a common data platform on chemicals Introduction Eurometaux acknowledges the European Commission’s efforts in establishing a common data platform on chemicals. By ensuring that information within this platform is findable, accessible, interoperable, and reusable, the Commission aims to support the establishment of a monitoring and outlook framework for chemicals.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

FuelsEurope welcomes the opportunity to provide feedback on the Commissions proposal establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable. Better access to available high-quality data through a common data platform will benefit regulators, industry and other stakeholders.

OSOA – One Substance One Assessment - Proposte di regolamento relativo a una piattaforma comune di dati sulle sostanze chimiche e alla riattribuzione di compiti tecnici all'ECHA. Posizione di Cosmetica Italia Cosmetica Italia – associazione nazionale imprese cosmetiche, riunisce circa 630 aziende cosmetiche (per lo più PMI), rappresentative per il 90% del fatturato del settore, che nel 2023 ha raggiunto i 15.140…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The European Environmental Bureau (EEB) welcomes the Commissions proposals for One Substance, One Assessment (OSOA) to enhance the level of protection of the environment and human health against hazardous chemicals.

The European Federation of Pharmaceutical Industries and Associations (EFPIA) represents the biopharmaceutical industry operating in Europe. EFPIA welcomes the opportunity to provide our views on the One Substance-One Assessment (OS-OA) legislative package.

KTF supports the main objective of an OSOA approach under the CSS to improve the efficiency, effectiveness, coherence, and transparency of issuing safety assessments of chemicals across different pieces of EU legislation.

AIC represents the cosmetics sector in Portugal and is affiliated to Cosmetics Europe. The CIE supports an OSOA approach within the HSC to improve the efficiency, effectiveness, coherence and transparency of chemical safety assessments in different pieces of EU legislation.

Filed in Portuguese · English published by the European Commission

LOréal welcomes the opportunity to comment on this ambitious proposal to improve data access for safety assessments. As a worldwide leader in the beauty market founded almost 115 years ago by a chemist, we are engaged in fundamental research to develop innovative ingredients.

STANPA endorses the "One Substance, One Assessment" approach as delineated in the European Union's Chemicals Strategy for Sustainability (CSS). We wish to offer our insights on the legislative proposals concerning the establishment of a Common Data Platform on Chemicals and the reassignment of tasks to the European Chemicals Agency (ECHA).

Japan Chemical Industry Association (JCIA) appreciates the opportunity to provide the following comments in response to the proposal. JCIA respects the ambition of the European Chemicals Strategy for sustainability, which calls for the safe management of chemicals.

Being a cross-sector association with member companies operating in different industries and stages in the supply chain (electronics, chemicals, polymers, automotive, machinery, semiconductors, wholesale trade, precision instruments, pharmaceutical, steel, nonferrous metal, textiles, ceramics, and glass products), JBCE welcomes the opportunity to contribute to the discussion regarding the proposal for Chemicals…

Cosmetics Europe supports the main objective of an OSOA approach under the CSS to improve the efficiency, effectiveness, coherence, and transparency of issuing safety assessments of chemicals across different pieces of EU legislation.

ClientEarth welcomes the Proposal for a Regulation establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable and establishing a monitoring and outlook framework for chemicals published by the European Commission on 7 December 2023 as part of the One Substance One Assessment package.

PUB/24/KH/37715 CropLife Europe key comments on legislative proposals linked to One Substance One Assessment CropLife Europe welcomes the opportunity to provide comment on the initiatives in the public consultation on “Chemical Safety – better access to chemicals data for safety assessments” and “Chemicals – making best use of EU agencies to streamline scientific assessments” Both comments on the draft regulation…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We, as the manufacturer of industrial measuring and monitoring equipment (RoHS Category 9 equipment), are very concerned about the intention to ensure that test reports, wherever applicable, become part of the technical documentation and must be kept by us to demonstrate RoHS compliance of our equipment.

Filed in German · English published by the European Commission

Please receive in attachment the FEFANA's feedback on the proposal for a Regulation establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable and establishing a monitoring and outlook framework for chemicals.

Federchimica supports the creation of a common data platform, which would allow the information to be consolidated in one position: this chemical lindustria platform calls for better communication and coordination of the different regulatory processes, thus enabling the improvement and enhancement of the safety assessment of chemicals.

Filed in Italian · English published by the European Commission

Novonesis is supportive of the intention behind the One Substance, One Assessment initiative. Novonesis supports the European Commissions ambition about streamlining of substances across EU legislations and strengthening the knowledge about substances and act on new chemical risks when they occur. This initiative will make better risk assessment and increase transparency for consumers and researchers.

We, as the manufacturer of industrial measuring and monitoring equipment (RoHS Category 9 equipment), are very concerned about the intention to ensure that test reports, wherever applicable, become part of the technical documentation and must be kept by us to demonstrate RoHS conformity of our equipment.

Filed in German · English published by the European Commission

Eurocolour welcomes the establishment of a common data platform to support sound scientific hazard and risk assessments. But there are still some areas of concern in the draft which we would like to elaborate on: Make best use of industries expertise: The establishment of the common data platform will be a complex and time-consuming task.

Please see the attached document on behalf of the Titanium Dioxide Manufacturers Association (TDMA) on the proposal for a Regulation on a common data platform on chemicals where we highlight Titanium Dioxide, the main substance we follow.

Merck welcomes the opportunity to comment on the proposals by the Commission to streamline regulatory processes and to improve cooperation between the agencies responsible for chemical management in the EU. Merck develops, manufactures, and markets high-quality medicines, innovative products for the biotech and pharmaceutical industries and for academic research as well as specialty chemicals for high-tech…

The German Social Security Fund (DSV) welcomes the Commission’s initiative to set up a single platform for chemicals to make data findable, accessible, interoperable and reusable for stakeholders. So far, chemical assessment has been a largely non-transparent process. This is due in particular to the fact that the bases leading to an assessment are not publicly available.

Filed in German · English published by the European Commission

Medicines for Europe, the European voice for the off-patent medicines, welcomes the possibility to give its views on the proposal for a regulation establishing a common data platform on chemicals. We believe in fostering a collaborative environment that ensures the safety of chemicals while facilitating access to essential products, particularly to generic, biosimilar and value-added medicines.

1. Avoid increased administrative burdens for business operators: The administrative burden on companies and the Agency has proven to be more time- and resource-intensive than initially anticipated. Not only the pre-submission phase but also the notification of studies should be proportionate and focused on contributing values to risk assessment. Flexibility should allow companies to use all kinds of studies.

BeST welcomes the Commission's current initiative. It should be in the interest of all parties involved to have improved access to, and use of data for safety assessments. The proposals will impact the entire metals, minerals and chemicals sectors and we rely on Eurometaux and Cefic to address the issues at stake for all. Below, we point out the key concerns for the Beryllium sector.

MedTech Europe, the European industry association representing manufacturers of medical technologies (medical devices and in vitro diagnostic medical devices- IVDs), takes the opportunity to share its views on the One Substance, One Assessment (OSOA) package of legislative proposals published on 7 December 2023.

Please see attached document for CEFIC's feedback on the proposal for a Regulation establishing a common data platform on chemicals, laying down rules to ensure that the data contained in it are findable, accessible, interoperable and reusable and establishing a monitoring and outlook framework for chemicals

Basically, VCI and its member companies welcome the establishment of a common data platform to support sound scientific hazard and risk assessments as well as best informed regulatory decisions while respecting efforts, ownership rights and confidential business information of companies.

Thank you for considering this public comment. 'Sec. 2. Legal Basis, Subsidiarity' express the core purposes of this Proposed Regulation [my emphasis]: “...The aim of providing a high level of protection of human health and the environment and of contributing to coherent safety assessments… The ultimate objective regarding information availability and information sharing is to collate all data on chemicals centrally…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Humane Society International/Europe (HSI/Europe) welcomes certain aspects of this proposal including the overall goal to support the FAIR principles for scientific data management and stewardship (Findability, Accessibility, Interoperability, and Reuse) to make data available and more easily used across the different chemical legislative frameworks.

The Federal Association for Animal Health (BFT) welcomes in principle this initiative with the aim of developing better access to chemical data for safety assessments. In particular, we support initiatives to gather publicly available information and assessments in a single resource. It is useful to rationalise the flow of data on chemicals between authorities of different sectors at national and European level.

Filed in German · English published by the European Commission

The RSC welcomes the proposed initiative on Chemical safety – better access to chemicals data for safety assessments. Scientists and technical review panels across member states and at the EU level need access to consistent scientific data so important chemicals safety decisions can be taken in full knowledge that all the evidence is shared, accessible and understood by all.

CEVA Santé Animale, member of AnimalhealthEurope, welcomed the objectives of this initiative in order to develop better access to chemical data for safety assessments. In particular, we support initiatives to compile publicly available information and assessments into a single resource.

Filed in French · English published by the European Commission

Havepharm (Member of AnimalhealthEurope and Hellenic Association of Representatives, Importers and Preparators of Veterinary Medicinal Products) welcomes the objectives of this initiative aimed at developing better access to chemical data for safety assessments. In particular, we support initiatives to gather publicly available information and evaluations in a single source.

Filed in Greek · English published by the European Commission

AnimalhealthEurope is the EU trade association representing manufacturers of animal medicines, vaccines and other animal health products in Europe. AnimalhealthEurope welcomes the objectives of this initiative with the goal to develop better access to chemicals data for safety assessments. In particular we support initiatives to compile publicly available information and assessments in a single resource.

The Packaging Inks Joint Industry Task Force (PIJITF), representing the packaging inks value chain, welcomes the European Commission’s intention to improve the availability of chemical data and exchange of information among the EU agencies.

Vetoquinol welcomes the objectives of this initiative with the goal to develop better access to chemicals data for safety assessments. In particular we support initiatives to compile publicly available information and assessments in a single resource. We note that the primary aim is to better streamline the flow of data on chemicals between different sector authorities (EU and national).

Considering the period chosen for the present call, we would like to focus our input on one specific element: the need for an impact assessment. While the target of creating an open and common basis of data for various assessment through some convergence of different notification/authorisation regimes is appreciated, one cannot ignore the diversity and complexity of the legislations and data collection/assessment…

SIMV represents the companies manufacturing and responsible for placing on the French market medicines and diagnostics for pets and livestock. SIMV is a member of AnimalhealthEurope and as such echoes the position of AnimalhealthEurope, a European association representing manufacturers of veterinary medicines in Europe.

Filed in French · English published by the European Commission

MSD Animal Health welcomes the objectives of this initiative with the goal to develop better access to chemicals data for safety assessments. In particular we support initiatives to compile publicly available information and assessments in a single resource. We note that the primary aim is to better streamline the flow of data on chemicals between different sector authorities (EU and national).

ChemSec welcomes the Commission´s initiative and we support the aims listed. As identified in the fitness check, there is a need to enable data sharing and that both authorities, industry, NGOs and citizen should have better access to data on problematic substances. The reuse of data is an obvious way of decreasing the burden on both authorities and industry.

16 August 2022 Submitted via: Chemical safety – better access to chemicals data for safety assessments (europa.eu) European Commission Re: Comments of the American Chemistry Council on EU Call for Evidence: Chemical safety – better access to chemicals data for safety assessments On behalf of the American Chemistry Council (ACC)1, I am pleased to submit comments on the EU Call for Evidence: Chemical safety-better…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We appreciate and support the initiative of the European Commission with the goal to improve the availability of chemicals-related data for use in safety assessments across the different legislations. Put into practice the approach will be a milestone to improve public and environmental health.

Eurometaux welcomes the opportunity to contribute to the call for evidence in relation to the new European Commission initiative “Chemical safety – better access to chemicals data for safety assessments”. We support such an initiative which is in line with our industry effort to establish a common and robust dataset to be used for risk assessment, promoting the consistent reuse of data across various regulatory…

Elanco Animal Health welcomes the EU initiative towards a better access to chemicals data for safety assessment through simplification and reduction of administrative burden, while helping to minimize duplication of effort in data generation. In particular we support initiatives to compile publicly available information and assessments in a single resource.

Dopharma welcomes the objectives of this initiative with the goal to develop better access to chemicals data for safety assessments. In particular we support initiatives to compile publicly available information and assessments in a single resource. We note that the primary aim is to better streamline the flow of data on chemicals between different sector authorities (EU and national).

CropLife Europe (CLE) raises the following comments with regards to the Call for Evidence on Chemical safety – better access to chemicals data for safety assessments. Summary • The crop protection sector is typically a downstream user with respect to REACH, and is subject to more specific sectoral legislation.

We welcome the objectives of this initiative with the goal to develop better access to chemicals data for safety assessments. We support to better streamline the flow of data on chemicals between different sector authorities/agencies (EU and national). We are however concerned about (unintended) consequences and impact which will not have been investigated in a proper impact assessment.

The Netherlands would like to thank the Commission for its dedication and advances on the initiative regarding access to chemical data for safety assessments and for the opportunity to provide feedback. The initiative serves to improve access to information on chemicals.

ECETOC welcomes the opportunity to comment on this initiative, which would be a key step in the implementation of the “One Substance-One Assessment” action from the Chemical Strategy for Sustainability (CSS). Below you will find highlighted comments, more details can be found in the attachment. LEGISLATIVE PROPOSAL ON DATA ACCESS The use of a harmonised tool is positive.

FoodDrinkEurope supports this initiative, and we ask the Commission that the envisioned actions are developed in such a matter that an open and common collection of chemicals-related data for use in assessments of the safety of chemicals can warrantee the development of clear, standardised approaches/protocols on the use and access of data for hazard and risk assessments.

The European Printing Ink Industry Association (EuPIA) welcomes the opportunity to contribute to the initiative “Chemical safety – better access to chemicals data for safety assessments”, as the improved access to chemicals data originating from public authorities, private entities or scientific literature by removing technical and administrative obstacles to that access is especially important for downstream…

Cruelty Free Europe welcomes the European Commission’s initiative ‘Chemical safety – better access to chemicals data for safety assessments’ and is grateful for the opportunity to respond to the call for evidence. Please refer to the attached document for further details.

We welcome initiatives that aim to harmonise rules, but notes these often raise the overall cost and impact by harmonising to the highest common denominator. The key points we would like to emphasise in this consultation are: 1. The need to support investment in R&D and innovation in the EU, to avoid disincentives to investment through by allowing lower market entry costs to commercial competitors free-riders.

As part of the “one substance, one assessment” package, the Commission aims to improve access to chemicals data by removing technical and administrative obstacles, according to the principles that data should be easily findable, interoperable, secure, shared and reused by default. FuelsEurope welcomes the opportunity to provide input for the preparation of the Commission’s legislative proposal.

The German Statutory Accident Insurance (DGUV) is grateful for the possibility of making a contribution from the statutory accident insurance scheme in Germany to the consultation on chemical safety — better access to chemical data for safety assessment. The DGUV is the central association of industrial and commercial liability insurance associations and accident insurance institutions in the public sector.

Filed in German · English published by the European Commission

The Polish Union of the Cosmetics Industry welcomes the Commission's proposal on better access to data on chemicals for the purposes of safety assessment. This initiative will help to improve the flow of data on chemicals. Better access to data on chemicals will allow the use of various sources, greater availability of information and a positive impact on the use of data.

EMODnet Chemistry - the marine water quality data infrastructure - welcomes the EC initiative for improving access to chemicals data to support safety assessments. Since 2009 EMODnet has been the key EU long-term initiative supported by DG MARE to ensure that European marine in situ data become easily accessible, interoperable and free from restrictions on use.

Plastics Recyclers Europe (PRE), the association representing the plastics recycling industry, welcomes the utilization of all data for holistic evaluation of chemicals and acknowledges that more can be done to achieve synergies in the utilization of data at the European level. Please find more details in the attachment.

A.I.S.E., the International Association for Soaps, Detergents and Maintenance Products, welcomes the opportunity to comment on the European Commission’s initiative ‘Chemical safety – better access to chemicals data for safety assessments’. As an organisation founded on the principles of sound science, constructive stakeholder dialogue and clear and transparent communication, A.I.S.E.

Cefic supports re-use of chemical safety data by public authorities in charge of the implementation of EU chemicals legislation, as an enabler of “One Substance-One Assessment’. Applying the ‘originator’ principle as a mechanism to overcome legal barriers to re-use by authorities of data generated by industry would ensure legal foreseeability and consistency of decisions on data treatment.

The objectives set out in the CSS, in line with the relevant Council Conclusions, set the path towards a safer and more sustainable management of chemicals. Information on substance properties and conditions of production, processing and use is crucial for the sound assessment and management of chemicals.

The Downstream User of Chemicals Coordination Group (DUCC), representing 11 European associations whose member companies use chemicals to formulate mixtures raises the following with regards to the proposal of Commission to remove ‘improve access to chemicals data by removing technical and administrative obstacles’.

AESGP, the Association of the European Self-Care Industry, represents the manufacturers of non-prescription medicines, food supplements, and self-care medical devices in Europe, an area also referred to as “self-care” or “consumer healthcare” products.

Chemical Safety – better access to chemicals data for safety assessments Call for evidence for an initiative (without an Impact Assessment) Introduction The EPMF welcomes the opportunity to input into the call for evidence regarding the better access to chemicals data for safety assessments.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EC public consultation/ Call for evidence: Chemical safety – better access to chemicals data for safety assessments (europa.eu) FEFANA position FEFANA1 is the united voice of the specialty feed ingredients2 (SFIs) industry in the European Union. Specialty feed ingredients are key elements for optimized feed formulations.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The overall “chemical platform” proposal, and the new related legislation is expected to cover not only “better access to” chemical data but also the (re)use of data by the Agencies/JRC to support the safety assessment(s). Having access to data (well defined, well structured, with proper metadata, standard formats, in a central or federated storage system) is not enough if Agencies/JRC are not able to use that data.

Stockholm University welcomes and supports the Commission´s initiative for ‘one substance – one assessment’ and better access to chemicals data for safety assessments. Access to data is fundamental for health and environmental assessments and for the transition to a toxic-free circular economy. Improved access to data has the potential to reduce delays and redundancies in chemical regulation.

We welcome the initiative for better access to chemicals data for safety assessments. There is a great potential for increasing re-use of data and transparency across different regulatory processes dealing with safety assessment of chemicals. We would be grateful to be included in the targeted stakeholder consultation.

August 2022 Cefic response to Call for Evidence - ‘better access to chemicals data for safety assessments’ We support the re-use of chemical safety data to enable ‘One Substance One Assessment’ and a balanced dissemination of chemical safety information which incentivizes companies to invest in safety data generation, in full trust that their data will be protected from unfair use by competing entities whilst…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Aafa is the professional trade union of actors in the growing media sector, mulching, organic soil improvers, organic and organo-mineral fertilisers and biostimulants. Representing almost 100 manufacturers of innovative fertilising materials and inputs to sustainable plant crops, AFAï A thanked the competent authorities for this initiative, which would improve access to data from chemical safety assessments.

Filed in French · English published by the European Commission

NIA feedback – Call for evidence on the initiative Chemical safety – better access to chemicals data for safety assessments (August 2022) The Nanotechnology Industries Association (NIA) welcomes the opportunity to provide initial feedback on the Commission initiative to present a proposal for a Regulation to streamline and improve access to chemicals data for the purpose of safety assessments.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

It is currently not possible to perform in-depth environmental and health risk assessments of all chemical substances in use in the EU, because of the great variety of chemicals, their diverse uses, and data gaps. This may put workers, consumers, and the environment at unnecessary risks, so the situation must urgently be addressed.

This initiative is closely linked to the concept of ‘one substance, one assessment’, strived for under the EU Green Deal and its Chemicals Strategy for Sustainability. This concept promises some improvements in substance evaluation but at the same time it also harbours many pitfalls that might cause serious damage to EU’s industry.

This initiative is closely linked to the concept of ‘one substance, one assessment’, strived for under the EU Green Deal and its Chemicals Strategy for Sustainability. This concept promises some improvements in substance evaluation but at the same time it also harbours many pitfalls that might cause serious damage to EU’s industry.

Women Engage for a Common Future (WECF) welcomes the proposal of the Commission on better access to chemicals data for safety assessments. This proposal will help have better chemical evaluation and speed up the evaluation process. Openess of data will reveal data gaps on chemicals (notably gender specific data) and show that current evaluation process does not take sufficiently these aspects under account.

Venator is a leading chemical company focused on the development and manufacture of titanium dioxide pigments and performance additives that improve the quality of life for consumers everywhere. We support the initiative to remove technical and administrative obstacles and the streamlining of data flows between agencies.

While this is a laudable endeavour in itself, it is very important, in addition to harmonisation, to assess more closely the authorisation of new substances. Too often substances are first authorised and later it appears that this should not have happened. Examples of: CFCs, PFAS and continue.

Filed in Dutch · English published by the European Commission

• The Regional Ministry of Agriculture, Rural Development, Climate Emergency and Ecological Transition considers that a prior step in the context of chemical substances for safety assessments involves the control of pesticides used in crop protection.

Filed in Spanish · English published by the European Commission

The European Federation of Pharmaceutical Industries and Associations (EFPIA) represents the biopharmaceutical research based industry operating in Europe. It is essential for EFPIA that any actions on implementation of the One Substance One Assessment (OSOA) concept as part of the EU chemicals strategy for sustainability do not have a negative impact on ensuring the access of safe, efficient medicines and vaccines…

The European Marine Board (EMB) welcomes the ‘Chemical safety – better access to chemicals data for safety assessments’ initiative. As outlined in the EMB’s Future Science Brief No. 6, Findable, Accessible, Interoperable, and Reusable (FAIR) data is an important pre-requisite to a big data approach.

CHEM Trust welcomes the Commission´s initiative and would like to express support for the proposed key actions. Removing current legislative obstacles to the re-use of data will help to facilitate the work of regulatory agencies in the safety assessments of chemicals.

We support this initiative, in particular if you remove the ambiguities that exist in REACH registration (other names, other CAS numbers, deleted CAS numbers, etc.). However, the data stored there must be verified and comply with REACH dossiers; not like CLP, where anyone can report/classify everything unchecked, and it is important to ensure that new results/findings are included in this register without delay…

Filed in German · English published by the European Commission

Chemical safety - better access to chemical data for safety assessments. To: European Commission DG ENV - B.2, From: Senior Corporate Silver Spoon, Environment & Nature Association TR ID: 30399232694-16 Subject: for a regulation proposal - as for Initiative. Magyarul: rendelet javaslathoz. Topic: Call for Opinions - Environmental Protection.

Filed in Hungarian · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This initiative is remarkable. Just one comment about:"create a data-generation mechanism for EU and national authorities and oblige industry and (external) testing laboratories to notify these authorities of any studies they commission, based on existing notification rules in the food sector.". This obligation has a negative impact on basic research about NAMs (New Approach Methodologies).

The initiative is sound. I would like to point those responsible for "oblige the Commission and EU agencies to operate an open platform for data on chemicals and its building blocks" to the work being carried out in the H2020 research and innovation action project ZeroPM: zero pollution of persistent, mobile substances for which I coordiante.