European Chemicals Agency and amending regulations

The German Animal Welfare Association welcomes the valuable opportunity to provide feedback on a basic regulation to the European Chemicals Agency (ECHA). The initiative aims to strengthen ECHA’s governance and make it fit for the future, as well as to implement financial sustainability.

Filed in German · English published by the European Commission

Cosmetica Italia is the association representing the cosmetics and personal care industry at national level. With a market value of EUR 13.4 billion, the sector employs 36.000 people, up to 400.000 if we consider the entire sector.

Filed in Italian · English published by the European Commission

02 December 2025 Comments on the Proposal for Regulation of the European Parliament and of the Council on the European Chemicals Agency and amending Regulations (EC) No 1907/2006, EU No 528/2021, (EU) No 649/2012 and (EU) 2019/1021 The International Federation of Essential Oils and Aroma Trades (IFEAT) welcomes the opportunity to comment on the proposal and support its core aim of establishing a self-standing legal…

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

DUCC position on the proposal for a Regulation on the European Chemicals Agency 2 December 2025 The Downstream Users of Chemicals Co-ordination Group (DUCC) is a platform of 11 European associations which represent “downstream” industries ranging from cosmetics and detergents to aerosols, paints, inks, toners, pressroom chemicals, adhesives and sealants, construction chemicals, fragrances, disinfectants, lubricants…

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

Eurometaux welcomes the opportunity to provide feedback the proposed Basic Regulation for the European Chemicals Agency (ECHA). We acknowledge the significance of this legislative initiative, considering ECHAs evolving mandate that has expanded well beyond REACH to encompass more broadly chemicals management and areas such as batteries, waste, RoHS, POPs, and cross-border threats.

We welcome the Commissions proposal for a Regulation of the European Parliament and of the Council on the European Chemicals Agency (ECHA) and support its core aim of establishing a self-standing legal framework with stronger governance for the Agency.

COSMED welcomes the possibility to comment on the proposal which aims to strengthen the governance of ECHA. We fully understand the need to ensure the best use of expertise and resources of European agencies, however we stress that it is also essential to keep an efficient process ensuring a high level of protection of human health and a well-functioning internal market.

Cruelty Free Europe thank the Commission for the opportunity to provide a second round of feedback on the proposal for an ECHA Basic Regulation, following the publication of the proposed text. ECHA is perfectly positioned at the interface of chemical safety and the advancement of regulatory toxicity testing to play a pivotal role in Europes transition away from the use of animals in science.

1 December 2025 Cefic Input to the Public Consultation on the proposal for a Regulation on the European Chemicals Agency (ECHA Basic Regulation) Cefic supports a well-functioning European Chemicals Agency (ECHA) to deliver science based and technical tasks on chemical safety assessment. Any new task needs to be linked with ECHA’s vision and mission with appropriate human and financial resources allocated.

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

ACEA the European Automobile Manufacturers Association thanks the European Commission for the opportunity to provide comments on the European Chemicals Agency proposal for a basic regulation. We wish to express our support for the proposed regulatory amendments that strengthen the functioning and capacity of ECHAs scientific committees.

We wish to emphasize the importance of the objective of transitioning to non-animal chemical safety assessment, in line with the roadmap toward phasing out animal testing, currently being finalized, and the 2021 Parliamentary resolution. This means integrating non-animal approaches into overall strategy, annual programming and resource allocation.

The German Social Insurance Agency (Deutsche Sozialversicherung – DSR) expressly welcomes the fact that a separate legal basis will be created for ECHA in the future. A clearly defined legal framework can help strengthen ECHA’s governance structures and enable it to continue to carry out efficiently and independently the tasks that have been steadily growing since its creation.

Filed in German · English published by the European Commission

The European Federation of Essential Oils (EFEO) welcomes the opportunity to comment on the proposal and support its core aim of establishing a updated self-standing legal framework and stronger governance for the European Chemicals Agency.

The International Fragrance Association (IFRA) welcomes the European Commissions proposal for a Regulation on the European Chemicals Agency (ECHA) and its objective to reinforce the Agencys governance and scientific structures.

The proposal provides ECHA with a single legal framework fit for its extended mandate. Further clarification is needed on its objectives, committees, inter-agency cooperation, financial provisions, independence, transparency and rigorous management of conflicts of interest.

Filed in French · English published by the European Commission

The IGBCE welcomes the opportunity to comment on the proposal and expressly supports the central objective of modernising the ECHA, strengthening its mandate and further expanding its role as an international reference in chemical assessment. Our detailed comments on the points we consider particularly important can be found in the attached document.

The European Environmental Bureau welcomes the Commissions proposal for the ECHA Basic Regulation to improve ECHA's governance and financial model as its mandate grows. We provide the following recommendations to further strengthen protection of people and nature from harmful chemicals.

PPAM de France welcomes the opportunity to comment on the proposal and support its core aim of establishing a self-standing legal framework and stronger governance for the Agency. Beside this, we want to comment on the essential role of the Scientific Committee on Consumer Safety (SCCS) and to stress the importance of ensuring that its valuable work continues effectively under the framework of the European Chemicals…

Eurogroup for Animals welcomes the European Commissions proposal to modernise the mandate and governance of the European Chemicals Agency (ECHA). We are pleased to have the opportunity to provide input and would like to take this opportunity to emphasise the need to further strengthen the integration of non-animal approaches within ECHAs mandate, strategic planning, reporting, and operational practices.

The proposed amendments affecting biocidal products, in particular the inclusion of the Committee for Socio-economic Analysis (SEAC) in the evaluation processes and the structural simplification of the text, are conducive to more consistent regulation capable of taking into account the real health impact of biocides on the population.

Filed in French · English published by the European Commission

CLEPA, the European Association of Automotive Suppliers, thanks the European Commission for the opportunity to provide comments on the European Chemicals Agency proposal for a basic regulation. We wish to express our support for the proposed regulatory amendments that strengthen the functioning and capacity of ECHAs scientific committees.

Humane World for Animals welcomes the opportunity to comment on the Commissions adopted act for a Regulation establishing the European Chemicals Agency (ECHA). We strongly support the proposals objective to improve and streamline the Agencys governance and create a more sustainable and predictable financial system.

The Health and Environment Alliance (HEAL) welcomes the proposal for an ECHA Basic Regulation (COM(2025) 386), aiming to strengthen the governance of the European Chemicals Agency (ECHA) and to increase the sustainability of its financing model, especially considering the existing and planned reassignment of new scientific and technical work to the agency.

ECHAs responsibilities in commissioning and evaluating tests are expanding. The draft Regulation strengthens its role, improving governance, transparency, and coordination with Member States (MS). We welcome this draft as it provides a solid institutional basis for promoting human-relevant approaches and modernising EU chemical safety assessment.

Agence européenne des produits chimiques – Proposition de Règlement de base La réglementation actuellement applicable à l’Agence européenne des produits chimiques (ECHA) remonte à 2006. Depuis 2008, l’ECHA s’est vu confier de nouvelles tâches arrêtées dans plusieurs actes législatifs et accords ponctuels.

Filed in French · English published by the European Commission

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

The European Commissions proposal to establish a standalone regulation for the European Chemicals Agency (ECHA) represents a shift in how the EU governs chemical risk. The proposal formalizes ECHAs mandate outside of its previous anchoring in REACH and recognizes ECHAs increased scope of work on risk evaluation, cosmetic assessment, and coordination with other EU agencies and bodies.

One Voice is a French association that fights for the protection of animals and nature. We welcome the European Commission’s intention to establish a basic regulation for Lecha, designed to modernise its mandate, clarify its tasks and strengthen its governance.

Filed in French · English published by the European Commission

GAIA welcomes the revision of ECHAs founding regulation and stresses that the Agencys mandate must be fully aligned with the EUs chemicals sustainability strategy and with the legal obligation to reduce and replace animal experiments. Although REACH already requires the promotion of alternative methods and the use of animals only as a last resort, animal testing remains widespread.

We, Stichting Proefdiervrij, the Dutch Foundation for the Replacement of Animal Testing, are supporting the Commissions efforts to strengthen the European Chemicals Agency. We see great opportunities of this effort to support the agencys alignment with EU commitments, especially the transition away from animal testing. Our recommendations: 1.

The VCI supports an independent mandate for the work of the ECHA, its continuation, the planned strengthening of the RAC and SEAC committees, and sustainable financing for the agency. The opportunity should be taken to improve provisions with regard to communication between the Agency and duty holders as well as transparency. Both are key for efficient and effective implementation of sectoral legislation by ECHA.

ClientEarth welcomes this opportunity to provide comments to the legislative proposal COM(2025) 386. We fully support the objective of the initiative to strengthen the governance and financial flexibility of the Chemicals Agency, while ensuring it can deliver on its tasks deriving from the REACH Regulation and several other pieces of Union legislation relevant for chemicals.

As part of the European Commissions initiative to establish a Basic Regulation for the European Chemicals Agency (ECHA), we wish to express our strong support for maintaining the Scientific Committee on Consumer Safety (SCCS) as an independent, sector-specific expert body within the future structure of ECHA.

This Regulation represents an important opportunity to ensure ECHAs additional tasks are fully aligned with the objectives of the Chemicals Strategy for Sustainability (CSS), Directive 2010/63/EU on the use of animals for research and testing and key commitments under the Commissions Roadmap towards phasing out animal testing in chemical safety assessments.

LECHA plays a key role in the EU’s transition to animal testing as an impact on public health and the environment, as well as in responding to standards and the social context; it should therefore promote the development, validation of non-animal models as a matter of priority.

Filed in Italian · English published by the European Commission

PETA welcomes the Commissions initiative to provide ECHA with a stable governance framework, recognising its potential to advance humane and scientifically robust approaches to chemical safety assessment. However, the current text remains largely aspirational.

Participating in the European Commission call for evidence on biocides data protection The reason of ERCRS, S.A. feedback is that “The ómnibus” initiative explicitly raises the possibility of “amending the expiry date of all data protection.” This point is very important to us because since the beginnig of the biocidal regulation, our expenses on studies has been high.

Filed in Spanish · English published by the European Commission

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

SK REACH & CLP Competent Authority would like to express general observation on the proposal for a basic regulation of the European Chemicals Agency. In general, we can support the introduction of a more flexible ECHA financing model compared to the current one, which could better reflect new ECHA tasks stemming from actions of Chemical Strategy for Sustainability (CSS).

FEBEA brings together and represents more than 350 manufacturing companies selling cosmetics in France and internationally within the meaning of Regulation (EC) No 1223/2009 (perfumes, make-up, hairdressing products, care products and hygiene and toilet products), which are marketed through numerous distribution systems.

Filed in French · English published by the European Commission

Cefic supports a well-functioning European Chemicals Agency (ECHA) to deliver science based and technical tasks on chemical safety assessment. These tasks will become even more complex and challenging following the implementation of the EU Chemicals Strategy for Sustainability (CSS).

Dear Madam, Dear Sir, Many thanks for providing the possibility to participate to the Call for Evidence for the proposal for ECHA's basic regulation. Please find attached Eurometaux's contribution. Please do not hesitate to contact us if you need any clarification.

The need to use non-animal methods to the maximum possible extent and to transition away from testing on animals is clear. ECHA is very well placed to make valuable contributions to these efforts; the tasks and structures of ECHA must be fit for purpose.

ClientEarth welcomes the possibility to give feedback on this important initiative. We agree with the key points identified by the roadmap as the necessary scope of the action. Our comments address each of them. “Need to consolidate the purpose of ECHA considering the evolution of tasks” We are looking forward to the changes the Commission sees as needed on this aspect.

ECHA founding Regulation Feedback to Commission’s Call for Evidence 10 October 2022 The European Apparel and Textile Confederation (EURATEX) welcomes the Commission’s public consultation to revise the governance of the European Chemicals Agency (ECHA) as outlined in the Chemicals Strategy for Sustainability (CSS).

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

10 October 2022 PETA Science Consortium International e.V. response to the European Commission’s call for evidence on the ‘European Chemicals Agency – proposal for a basic regulation’ PETA Science Consortium International e.V.

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

10 October 2022 Submitted via: European Chemicals Agency – proposal for a basic regulation (europa.eu) European Commission Re: Comments of the American Chemistry Council on EU Call for Evidence: European Chemicals Agency – Proposal for a Basic Regulation On behalf of the American Chemistry Council (ACC)1, I am pleased to submit comments on the EU Call for Evidence: European Chemicals Agency – Proposal for a Basic…

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

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. AESGP welcome the opportunity to provide our feedback on the foreseen proposal for a founding regulation of the European Chemicals Agency (ECHA).

Eurogroup for Animals welcomes this initiative which aims to align the basic legal provisions establishing ECHA with its future roles. We support actions that can harmonise safety assessments across EU legislation, but this must reflect the EU’s commitment to reduce and replace animal testing for safety and risk assessment, and be based on full exploitation of the toolbox of New Approach Methodologies (NAMs).

The Polish Union of Cosmetics Industry hereby presents comments to the Call for Evidence regarding a „Proposal for a basic regulation of the European Chemicals Agency” with a particular focus on the Scientific Committee on Consumer Safety (SCCS).

Brussels, 10 October 2022 BeST position statement on a basic regulation for the European Chemicals Agency Introduction BeST submits the present position statement in the frame of the call for evidence on the proposal for a basic regulation of the European Chemicals Agency (ECHA).

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

AnimalhealthEurope represents the manufacturers of animal health products and services across Europe. AnimalhealthEurope supports the need to revise the legal framework of ECHA to reflect the additional roles it has been given since its formation, to bring its procedures and working practices into line with the other agencies and to place its finances on a more sustainable footing.

Proposal for a basic regulation of the European Chemicals Agency The European Chemicals Agency (ECHA) is a cornerstone in the EU’s chemicals legislation. Throughout its 14 years of existence it has been assigned new responsibilities continuously. This reflects its excellent execution of its tasks and the added European value of having one common agency for the Union.

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

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to provide comments to the call for evidence on the “European Chemicals Agency – proposal for a basic regulation”.

COSMED welcomes the possibility to comment on the proposal which aims to adjust the mandate and structure of ECHA. We embrace the objective of the CSS and fully understand the need to ensure the best use of expertise and resources of European agencies, however we stress that it is essential to keep an efficient process ensuring a high level of protection of human health and the environment and a well-functioning…

EFCTC contribution to the Commission Public Consultation on the proposal for a basic regulation for the European Chemicals Agency INTRODUCTION The European FluoroCarbons Technical Committee is a Cefic Sector Group.

WVMetalle would like to comment on the Europeans Commission proposal to revise the role of the European Chemical Agency (ECHA) with the aim to strengthen the governance and streamlining the working methods of ECHA bodies, while ensuring a more sustainable financing model.

The steel industry welcomes the Commission’s initiative to revise the basic Regulation (EC) No 1907/2006 (REACH) on the European Chemicals Agency (ECHA). In parallel with the ongoing development of chemicals and substance legislation, ECHA has been increasingly assigned tasks and competences.

Filed in German · English published by the European Commission

BDSV e.V. is the Federation of the German Security and Defence Industries and as such represents several companies that produce security and / or defence equipment in Germany. BDSV welcomes the opportunity to give input regarding the future workings of ECHA. 1) The future Basic regulation for ECHA should indeed make certain that ECHA has a well-based funding.

Maintaining a strong expert committee on cosmetics safety assessment that benefits an OSOA environment L’Oréal fully supports an EU strategy that aims to protect human health and the planet and step up the transition towards the use of more sustainable chemicals.

NOTAT Ref. Ares(2022)6985895 - 10/10/2022 Rent drikkevand og sikker kemi J.nr. 2022-11203 Oktober 2022 Commission call for evidence - proposal for a basic regulation of the European Chemicals Agency There has been a call for general election in Denmark to be held on 1 November.

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

Association for District Heating of the Czech Republic (ADH CR) welcomes opportunity to comment on the open call for evidence for an initiative „Proposal for a basic regulation of the European Chemicals Agency”. Please find detailed comments in the Attachment.

IFRA supports the European Commission’s willingness to adjust the mandate and structure of ECHA to optimise and rationalise how its bodies operate and increase the sustainability of its financing model. IFRA believes that this Regulation could be an opportunity to enhance the transparency of ECHA, make the best use of the expertise of its different bodies and improve the organisation of scientific committees to…

Tronox employs some 6,500 employees globally. Our diversity, unmatched vertical integration model, unparalleled operational and technical expertise across the value chain places Tronox as the global, leading titanium dioxide (TiO2) manufacturer.

Thank you for the opportunity to provide you with our comments, that focus on how the future regulation should integrate the Scientific Committee on Consumer Safety (“SCCS”) within ECHA. Namely: - any re-allocation of the work of the SCCS to ECHA should keep the specific and unique excellent expertise that the SCCS has gained since over than 40 years with regards to safety of cosmetic ingredients and products.

Comments by Division 4 Hazardous Substances and Biological Agents of the German Federal Institute for Occupational Safety and Health We welcome the initiative for a basic regulation for ECHA to strengthen its role as coordinating authority for regulatory actions in the field of chemical safety. ECHA’s coordination role is required, e.g.by organizing and hosting of committees, working parties, events etc.

We would like to thank the Commission for providing us with the opportunity to communicate our views on this important subject. Our Association fully supports the European Green Deal and the Chemicals Strategy for Sustainability and is committed to protect human health and the environment, supporting the transition towards the use of sustainable chemicals.

The bureaucratic burden on EU´s companies is significant. This is especially true for SMEs, which are struggling with the costs and complexity to implement the EU-legislation, which also includes the EU chemicals legislation.

Whilst Cosmetics Europe supports the CSS objective of improving effectiveness, efficiency and coherence of safety assessments across EU legislation, it respectfully submits that any re-allocation of the work of the SCCS to ECHA should uphold the specific and unique cutting-edge expertise that the SCCS has built up over more than 40 years with regards to safety of cosmetic ingredients and products.

JBCE are happy to have an opptunity for giving in our comment on the Scientific opinions on chemical substances based on existing tasks that may be transferred from RoHS Directive to the Committee for Risk Assessment. JBCE welcomes a better alignment of RoHS Directive with REACH Regulation regarding the assessment of restriction substances.

The functioning of the European Chemical Agency is defined in Title II of REACH assigning the duty of “managing and in some cases carrying out the technical, scientific and administrative aspects of this Regulation and to ensure consistency at Community level in relation to these aspects” (Art. 75).

Detic is the Belgian-Luxembourg association for producers and distributors of cosmetics, cleaning and maintenance products, adhesives and sealants, biocides and aerosols. Thank you for the opportunity to comment on the proposal for a basic regulation for EChA. Detic supports the comments made by A.I.S.E. and Cosmetics Europe. In general, we support a basic regulation for the funding of EChA.

The FBDI is grateful for the opportunity to comment on the European Commission’s proposal for a basic regulation for the European Chemicals Agency (ECHA). The FBDI welcomes and supports the proposal to centralise ECHA’s tasks in a regulation. This is the only way in which ECHA can properly carry out its tasks.

Filed in German · English published by the European Commission

The European Federation of Pharmaceutical Industries and Associations (EFPIA) represents the biopharmaceutical industry operating in Europe. It is essential for EFPIA that any actions as part of the EU Chemicals Strategy for Sustainability (CSS), do not have a negative impact on ensuring the access of safe, efficient medicines and vaccines to citizens in Europe.

Liebherr-Aerospace Lindenberg GmbH (LLI) is grateful for the opportunity to contribute some basic comments on the “Proposal for a basic regulation of the European Chemicals Agency”. 1. LLI is committed to the development of sustainable and environmentally friendly technologies, which is reflected in constant investments in research and development.

The Wdk supports the European Commission’s Chemicals Strategy for Sustainability and welcomes its intention to consolidate chemicals regulation both between different regulations, such as REACH and the Drinking Water Directive, and between Member States.

Filed in German · English published by the European Commission

Athena Cosmetics welcomes the aims of the Proposal for a basic regulation of the European Chemicals Agency (ECHA) to simplify and clarify the rules under which ECHA operates – in light of the additional tasks entrusted to ECHA and the upcoming implementation of other legislation under the Chemicals Strategy for Sustainability (CSS) – to ensure adequate safety assessments of chemical substances.

In our view, it is clear that ECHA’s workload is increasing and that this effort must be financed. However, more centralisation of tasks within an agency should be carried out where necessary and appropriate. Consequently, this should go hand in hand with greater efficiency and resource savings. Resources committed in the previously responsible bodies should also be freed up.

Filed in German · English published by the European Commission

The DGUV [German Statutory Accident Insurance] is the umbrella association for professional associations in this branch and governmental accident insurers. It looks after the joint interests of its members and promotes the work they do for the benefit of insured persons and enterprises.

Filed in German · English published by the European Commission

The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the EU Commission proposal for a basic regulation for the European Chemicals Agency (ECHA). HEAL fully supports this proposal, which is necessary in order for the Agency to properly carry out its tasks - the latter have significantly expanded since the Agency started operating and the implementation of the EU Chemicals Strategy for…

The motivation for a basic regulation on the function and operation of ECHA and its bodies against the background of the Green Deal and the CSS is understandable. We thank you for the opportunity to contribute some basic comments on this matter. (1) ECHA and its bodies follow the principle of sustainability and pay attention to the consideration of the interests of nature, society and economy in their work.

Filed in German · English published by the European Commission

The motivation for a basic regulation on the function and operation of ECHA and its bodies against the background of the Green Deal and the CSS is understandable. We thank you for the opportunity to contribute some basic comments on this matter. (1) ECHA and its bodies follow the principle of sustainability and pay attention to the consideration of the interests of nature, society and economy in their work.

We ask to consider some basic points with the aim that the new regulation does not enter into complete contradiction with the respect that all citizens and institutions should have for animals and nature: 1 - The total prohibition of experimentation with animals in the field of cosmetics.

1. The statement “This initiative is unlikely to have a significant impact on the economy, society or the environment” should be questioned if at the same time a significant share of ECHA’s funding is to be made up of new fees for services to industry — especially since fees are expected to be recurring annually if there is little change in the performance portfolio in order to make the fees more predictable. 2.

Filed in German · English published by the European Commission

Care should be taken to increase the acceptance of non-animal research methods for safety testing and to reduce animal testing. The wording of the laws must be clear and there must be no loopholes. Particularly in the field of testing endocrine disruptors, mixtures and polymers, care must be taken not to increase animal testing.

Filed in German · English published by the European Commission