Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

Aludec S.A. as a chemical user company wishes to assess very positively the proposed revision of the REACH regulation. We appreciate and support any initiative from the European Union aimed at better protecting the health of European citizens and protecting the environment.

Filed in Spanish · English published by the European Commission

An addendum from GLOBAL 2000: The 0.1 % limit for SVHCs is too high for many substances, such as endocrine disruptors or carcinogenic substances. It is well known that EDCS can be harmful even in the lowest doses, often even more harmful than in higher doses. Therefore, there should be no 0.1 % limit, but SVHCs should have to be declared IMMER.

Filed in German · English published by the European Commission

EDC-Free Europe coalition welcomes the EC plans for the revision of REACH so that the Regulation fully delivers on its objectives to ensure a high level of protection for human health & the environment, and on the commitments of the Chemicals Strategy for Sustainability (CSS). Inadequate control of endocrine disrupting chemicals (EDCs) under REACH is one of the crucial areas of concerns.

Thank you for the opportunity to make proposals to improve REACH. Global 2000, the Austrian environmental protection organisation, sees the following potential improvements for REACH: Article 33 should be revised: — Companies have to reply IMMER to consumer-Inn enquiries, even if no SVHC is included (otherwise, consumer does not know whether companies simply did not reply, if query was lost, etc.) — time limit of 45…

Filed in German · English published by the European Commission

Green Transition Denmark (GTD) welcomes the opportunity to provide feedback on the Commission’s discussions of the revision of EU’s REACH chemicals regulation. GTD is a Danish NGO working to promote a green and sustainable transition of society. We have many years of experience with the chemicals area and have especially focus on endocrine disrupters and other areas that are not covered by the REACH legislation.

Cruelty Free Europe sees the revision of REACH as an opportunity to move towards a modern EU regulatory system for chemicals based on non-animal methods. This would end the suffering of millions of animals and address citizens’ concerns while providing better information on chemicals for human health and the environment.

The 23 organisations forming this Coalition share a view on how the essential use concept (EUC) can be introduced in a way that will tackle actual risks and not slow down the regulatory process or lead to unintended, regrettable substitution.

EFEO response to the Inception Impact Assessment on the revision of the REACH regulation The European Federation of Essential Oils (EFEO) supports the objectives of the Chemicals Strategy for Sustainability (CSS) and welcomes the opportunity to comment on the Inception Impact Assessments (IIA) on the revision of the REACH regulation.

Filed in German · English published by the European Commission

As downstream users of chemicals, we want to assess positively the REACH review initiative. We consider that if the stated objectives are met, there would be an improvement in the health of workers and users of chemicals and of the environment in general.

Filed in Spanish · English published by the European Commission

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the oldest and biggest environmental NGO. We think that the quality of chemicals safety information in REACH documentation especially with regard to environmental safety, but even to health effects, is varying and in many cases very poor.

The Association of Lithuanian chemical industry enterprises welcomes the opportunity to express views for REACH Revision Inception Assessment public consultation. Chemical sector in the country is already facing a transition which comprise climate neutrality, digitalization, circularity objectives and implementation of the Chemicals Strategy for Sustainability.

The desire to protect and safeguard human health and the environment in which we live can only be a shared objective on the part of everyone with common sense. However, we perceive that the diverse mechanisms contained in European regulations, aimed at generalising, often give rise to interpretations, and do not take sufficient account of the specificities and operational needs of many sectors, especially with…

Filed in Italian · English published by the European Commission

MedTech Europe, the European trade association for the medical technology industry welcomes the opportunity to provide feedback on the upcoming revision of the Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH Regulation). We look forward to continuing to engage in this and other policy initiatives within the Chemicals Strategy for Sustainability.

Friends of the Earth Germany (BUND) welcomes the possibility to comment on the IIA REACH revision. Regularly performing product testing to check for REACH compliance and encouraging consumers to use their right to know (Article 33), BUND sees the urgency for action, regarding enforcement of REACH compliance and revising Article 33. Please see our further remarks in attached document.

The Zero Pollution Action Plan under the EU Green Deal rightfully focuses on the prevention of pollution first, based on the precautionary principle; principles enshrined in the TFEU. The prevention of pollution at the source has to include accelerated, concrete action under the REACH Regulation to prevent harmful substances from negatively impacting surface and ground water quality, including drinking water…

As an environmental scientist I support the goals of the Chemicals Strategy for Sustainability to propose new hazard classes and criteria within REACH. Endocrine, disruption, persistence and mobility should be included as novel hazard classes. Further, data availability should be improved to check the compliance and effectiveness of the regulation.

To whom it may concern Protecting human health and the environment while making use of hazardous chemicals is of utmost importance to A4E members. That is why we support the objectives of the REACh Regulation, and welcome its revision to ensure an even better protection of human health and the environment. We appreciate the opportunity to participate in this revision process.

Humane Society International (HSI) welcomes this opportunity to comment on the Inception Impact Assessment – Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals. By ensuring that the EU regulatory approach for chemicals is based on up-to-date science, the EU can contribute actively to reductions in animal use through a robust implementation of Directive 2010/63/EU – but…

The Spanish Ministry for Ecological Transition and Demographic Challenge welcomes the Commission´s initiative to revise the two main chemical´s regulation in Europe. The European Union has to be a global example of sound chemicals management. The sale of chemicals is estimated to double by 2030, making the proper management of chemicals key to achieving the Sustainable Development Goals.

Eurometaux welcomes the opportunity to provide feedback on the REACH IIA. Please find attached our comments. Please do not hesitate to contact us if you have any question. Eurometaux stands ready to contribute with the other stakeholders to ensure REACH delivers it full potential.

Registration: Quality dossiers are essential to evaluate potential risks and take appropriate regulatory decisions. Requests made by authorities should nevertheless be proportionate and avoid unnecessary burdens. Including information on environmental footprint in registration dossiers could create opportunities to better account for the lifecycle sustainability of substances in regulatory risk management.

FuelsEurope welcomes the opportunity to comment on the Commission Inception Impact Assessment on the targeted recast of the REACH Regulation. REACH is a comprehensive regulatory framework supported by the most advanced knowledge base at global level.

EuroWindoor appreciates the opportunity to provide feedback to the inception impact assessment on the revision of REACH Regulation. The small and medium sized companies of the European window, door and façade sector are downstream users at the end of a long supply chain and far away from the chemical industry.

The PETA Science Consortium International e.V. promotes robust non-animal testing methods that protect human health and the environment. We welcome the opportunity to comment on the consultation ‘Chemicals legislation – revision of REACH Regulation to help achieve a toxic-free environment‘. Please find our response attached.

A. Context, Problem definition We fully support the analysis of issues related to the knowledge gaps, combination effects, communication in the supply chain, evaluation, and enforcement. However it is both surprising and problematic that the description of the current issues with authorisation does not account for the problems that are the direct consequences of the incorrect interpretation of REACH.

PRODAROM member of IFRA welcomes the opportunity to comment on the EU Commission Inception Impact Assessment on REACH. Full comments are available in the IFRA response. The revision of the REACH regulation should be targeted and science based. The Commission should seek to build on the current solid and existing framework to make it more efficient, consistent and streamlined.

DIGITALEUROPE supports the ambition to manage substances to the best possible extent in order to protect human health and the environment. The REACH Regulation is a fundamental piece of legislation for the management of chemicals both in the EU and globally and across many industries, including the digital one. Therefore, DIGITALEUROPE welcomes the opportunity to provide input to the Regulation revision.

FRANCE CHIMIE WELCOMES THE OPPORTUNITY TO PROVIDE FIRST INSIGHTS AND SUGGESTIONS FOR THE REACH REVISION INCEPTION IMPACT ASSESSMENT PUBLIC CONSULTATION. France Chimie fully supports Cefic’s contribution to the inception impact assessment and reiterates the need for an improvement and a better implementation of REACH.

The Spanish National Association of Fertilizer Manufacturers (ANFFE) considers that REACH is suitable for its purpose and achieves its objectives. However, we understand that there are areas where improvements can be made, including the following: • Simplification of procedures for the authorization, registration and evaluation of substances. • Consistency between REACH and other laws.

The remit of the CII targets exclusively cases in which the potential risks posed by chemicals are limited to the workplace environment. In light of this, we would like to provide our feedback to the EC Inception Impact Assessment on the upcoming revision of the REACH Regulation.

Unilever is committed to making sustainable living commonplace and welcomes the Commission’s initiative to review the REACH Regulation as part of the EU Green Deal (EGD) and the Chemicals Strategy for Sustainability.

Jernkontoret, the Swedish Steel Producers’ Association, welcome the revision of EU legislation on REACH as a part of the Chemical Strategy for Sustainability. Jernkontoret agreed on the main goal for REACH and want to see how the IIA revision on REACH as part of the ongoing open consultation.

Filed in French · English published by the European Commission

The European steel industry, represented by EUROFER, welcomes the European Commission’s Inception Impact Assessment for the revision of EU legislation on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), which aims to clarify the interface between the REACH and other legislation and improving the overall REACH process.

PU Europe, the European Federation of PUR/PIR rigid polyurethane insulation manufacturers, appreciates the opportunity to contribute to the inception impact assessment for the revision of the REACH Regulation. Our industry acknowledges the non-disputable role that REACH Regulation has played over the last decades and stands ready to help achieving a higher level of protection of citizens and the environment against…

Eurogroup for Animals welcomes the Chemicals Strategy for Sustainability of the European Commission. As chemical policies affect the health, safety and welfare of humans and animals, these policies are of particular interest to Eurogroup for Animals and its 73 Member Organisations.

The European Recycling Industries’ Confederation (EuRIC) welcomes the Inception Impact Assessment on the revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) and its main objective to transition towards a clean Circular Economy.

Stora Enso is a renewable materials company that employs over 18 000 people in the EU. With our renewable, recyclable raw material, wood, we operate at the heart of the circular bioeconomy. We deliver products that store carbon and provide low-carbon alternatives to non-renewable products. Stora Enso’s obligations under REACH are both as a manufacturer of articles and substances and as a downstream user.

Eurima supports the once-in-a-decade exercise by the European Commission to revise and update the REACH Regulation. Our association represents European Mineral Wool Insulation Manufacturers. The mineral wool fibres manufactured by our members are registered under REACH and we have a long history of cooperating with EU policy makers to ensure the highest standard of safety of our products.

ESIA represents the European semiconductor sector where companies are operating and competing in Europe and globally. The landscape of the REACH regulation and the uncertainty it brings to their manufacturing process in Europe compared with other regions of semiconductor production is one critical area of consideration under a targetted revision of REACH.

Derogations – Although the IAA does not propose to change the procedures to for adding substances to Annexes IV and V, the criteria to be fulfilled to amend Annexes IV and V remain unjustifiably burdensome. This means that it is hardly envisaged that new substances or groups of substances will be able to achieve derogations under the REACH regime.

Section A. Data availability: In addition, the lack of relevant toxicokinetic information should be addressed. Also the requirements for providing information on uses are insufficient for the purpose of risk assessment as well as communication along the supply chain.

CLEPA welcomes the opportunity to provide feedback on the inception impact assessment. When REACH was developed and implemented, its impact on business and society was assessed by the Commission. However, we found that the resulting numbers and conclusions did not represent our business realities, and instead broadly underestimated the real resulting costs and efforts.

The REACH Regulation is an essential tool for chemicals control in Europe. However, it needs to be improved to support the implementation and the level of ambition of the Chemicals Strategy for Sustainability (CSS).

The EU already has one of the strongest chemicals legislation in the world. Further tightening would disproportionately burden businesses and jeopardise competitiveness. Instead, the focus should be on uniform and practical enforcement. We reject a move away from risk-based chemicals regulation.

Filed in German · English published by the European Commission

Animal testing is unethical, abusive and unnecessary. Living, breathing organisms are as sensitive and often even more than human beings are. What you do to others (includes animals) will come back to you is karma. So why harm others? Living in a natural and organic world is better for everyone as organic waste recycles itself naturally endlessly. Toxic chemicals poison the environment and that's not what we want.

EuroCommerce supports the objectives of the Chemicals Strategy for Sustainability to better protect citizens and the environment against hazardous chemicals and encourage innovation for the development of safe and sustainable alternatives, and – as one of its actions – a targeted revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) regulation.

EDRA (European DIY Retail Association) represents European DIY retailers. Our positon on the review of REACH is as as follows: 1. Establishing a policy mix to de-risk innovation and improve the business case for safer chemistries and technologies Business and technology research indicates that innovation requires both willingness as well as capacity and opportunity to innovate.

Thank you for the opportunity to provide feedback on the proposed initiative to revise the REACH Regulation to better achieve the objectives of the Chemicals Strategy for Sustainability. IPC is a global association that helps original equipment manufacturers, electronics manufacturing services, printed circuit board manufacturers and suppliers to build electronics better.

The Danish Consumer Council Think has been working for years to remove harmful and undesirable chemistry from consumer products. The Danish Consumer Council Think is working to give visibility to the location of the harmful and suspected chemistry and advise consumers to make an informed choice.

Filed in Danish · English published by the European Commission

Comments from the Irish Health and Safety Authority on the Inception impact assessment for Revision of EU legislation on Registration, Evaluation, Authorisation and Restriction of chemicals (REACH) The Health and Safety Authority is the lead competent authority for the REACH Regulation in Ireland.

Hazardous chemicals have been identified as a significant concern for EU citizen and phasing them out is a key part in transforming the EU into a safe and sustainable market. The Chemical Strategy for Sustainability lists many of the main changes necessary.

The DyStar Group, a leading dyestuff & chemical manufacturer and solution provider, offering customers across the globe a broad portfolio of colorants, specialty chemicals, and services, welcomes the opportunity to give feedback on the REACH Regulation revision inception impact assessment.

The European PVC Profiles and related Building Products Association EPPA represents the manufacturers of PVC window systems and related building products in Europe. About 25,000 employees process about 1, 4 million tonnes of PVC creating a turnover of €4 billion with profile systems and building products.

COSMED welcomes the opportunity to provide its feedback on the intended revision of the REACH Regulation. Please find our full contribution in attachment. COSMED is the French cosmetic association for SMEs, a non-profit seeking association with more than 920 members, in France and Europe.

PlasticsEurope and its members, welcome the opportunity to contribute to the European Commission's inception impact assessment on revision of the REACH Regulation. Via the attached document, feedback is provided on the problems this initiative aims to tackle. About PlasticsEurope: PlasticsEurope is the pan-European association of plastics manufacturers.

The European Copper Institute welcomes the opportunity to participate in the public consultation on the Inception Impact Assessment for the Revision of REACH. Please find our response in the attached file. ECI is the voice of the International Copper Association (ICA) in Europe.

COCIR represents the medical devices technology sector in Europe (medical imaging, radiotherapy and health IT) and welcomes the EC proposal to review the REACH Regulation in the light of the new Chemical Strategy for Sustainability (CSS).

COCIR represents the medical devices technology sector in Europe (medical imaging, radiotherapy and health IT) and welcomes the EC proposal to review the REACH Regulation in the light of the new Chemical Strategy for Sustainability (CSS).

While medicines are exempted from REACH, bans and restrictions on substances used in manufacturing can be prohibitive for the production of certain medicines or diagnostics as often no suitable alternatives are available.

The European Copper Institute welcomes the opportunity to participate in the public consultation on the Inception Impact Assessment for the Revision of REACH. Please find our response in the attached file. ECI is the voice of the International Copper Association (ICA) in Europe.

Technology Industries of Finland’s comments on the Inception Impact Assessment of the revision of REACH and CLP regulations The Finnish Technology Industries promotes competitiveness and operational preconditions of technology industry companies, the largest and most important export sector in Finland.

The Confederation of Swedish Enterprise welcomes the European Commission’s Chemical strategy for sustainability and a revision of REACH that make the legislation and more effective. This combined with a strong and coordinated enforcement across the Union will protect consumers, environment and ensure a level playing field and competitiveness for business. Our input is further developed in the attached file.

Filed in Swedish · English published by the European Commission

SEMI Europe welcomes the opportunity to provide its feedback on the intended revision of the REACH Regulation. We would like to submit comments on the following policy options: • Revision of the registration requirements • Simplifying communication in the supply chain • Reforming the authorization process/Reforming the restriction process Please find our full feedback in the attached file.

Drinking Water Company Oasen (The Netherlands) strongly supports the ambition in the Chemicals Strategy for Sustainability to introduce endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern within REACH.

Mengend Nederland comments on the public consultation on the In-ception Impact Assessment on the revision of REACH Mengend Nederland1 supports the objectives of the CSS to achieve a higher level of protection of citizens and the environment against hazardous chemicals.

The roadmap shall contribute, inter alia, to the European Green Deal and to the Chemicals Strategy for Sustainability (CSS). The CSS formulates a long-term vision for EU chemicals policy that is based on a new “Toxic-free hierarchy” in chemicals management. The hierarchy prioritizes the promotion of safe and sustainable chemicals over minimisation of exposure and risk control and the last resort of elimination (e.g.

EURATEX, the European Textile and Apparel Confederation representing the European textile and apparel industry, welcomes the opportunity to provide feedback on the Roadmap of the revision of the REACH Regulation. We support the aim of the Commission to improve the current text of REACH and pursue the objectives of protecting human health and the environment and promoting innovation for companies.

Addressing the REACH revision roadmap, the Polish Union of the Cosmetics Industry would like to highlight the following issues: Revision of the registration requirements The introduction of new information requirements (hazards of concern, documentation of safe use, registration of certain polymers, and information on the environmental footprint) should be consistent with the requirements of Article 13 of REACH and…

Chemicals are everywhere in our daily lives and the role of the chemical industry in the EU green transformation is of paramount importance. REACH is the most comprehensive regulatory framework securing safe use of chemicals and the last evaluation of REACH (in 2018) has brought the European Commission to say that REACH Regulation is effective, fit for purpose and delivering on its objectives.

Eurogypsum, the association representing the interests of the European industry extracting and processing gypsum, welcomes the inception impact assessment on the revision of the EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH Regulation).

The European Solvent Recycling Group — ESRG — are supportive of the main aims of the proposals. In respect of the Circular Economy, ESRG would like to see updated guidance offered to Member States in respect of management standards for full coverage derived from wastes and the use of exemptions to support both REACH and in turn CLP.

Filed in German · English published by the European Commission

Supply Chain Communication: We welcome the opportunity to use extended SDS for the communication on hazard, risk & exposure for substances and mixtures. Standardized formats and details of the communication in the supply chain, especially digitally, should be agreed on after involvement of all stakeholders, e.g. in established standardisation bodies.

REACH plays a vital role in reducing chemical risks in Europe and globally; still, REACH suffers from major shortcomings, as correctly outlined in the Inception Impact Assessment (IIA). Thus, BEUC welcomes the Commission’s intention to revise REACH to achieve the goals of the Chemicals Strategy (CS). The IIA is however ambiguous and presents several CS actions as optional or omits them entirely, e.g.

JRAIA acknowledges that changes to the REACH regulation will lead to increased costs for industry throughout the supply chains. Furthermore, EU policy options contribute to keeping climate and environmental impacts need to be considered energy efficiency in parallel which is currently proposed in the European Green Deal.

The Euroepan Solvent Recycler Group - ESRG - are supportive of the main aims of the proposals. In respect of the Circular Economy, ESRG would like to see updated Guidance offered to Member States in respect of managing standards for full recoveries derived from wastes and the use of exemptions to support both REACH and in turn CLP. B. Freitag ESRG-Secretariat

Brussels, 01 June 2021 European Chemical Employers Group’s submission on REACH Revision Inception Impact Assessment ECEG welcomes the opportunity to provide suggestions for the REACH Revision Inception Impact Assessment public consultation. We had already an opportunity to express our views on REACH in chemical social partners’ joint statement on Chemical Strategy on Sustainability (CSS).

We agree with the EC assessment that "the current restriction process is too slow to sufficiently protect consumers and professional users against risks from the most hazardous substances" and "the normal restriction procedure, through specific risk assessment, puts a high burden on authorities".

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals which aims at protecting people and the environment with regard to hazardous chemicals, and at encouraging innovation for the development of safer…

To whom it may concern, We are a manufacturer, importer, distributor and user of chemicals and thus, fulfil all roles under REACH. The safe, responsible and sustainable use of chemicals is our highest principle. REACH (Regulation (EC) No 1907/2006) is a milestone in chemical regulation and sets a high level of protection of human health and the environment. It can be said with confidence, that REACH is a success.

The Slovenian chemicals industry spent significant resources for the implementation of the REACH-regulation since 2007. Fundamental changes in chemicals management was necessary. For our industry this was in particular burdensome, because it is highly SME-structured.

The European Green Deal presents a unique opportunity for the EU to radically scale up and speed up actions to protect its citizens and ecosystems from the risks of exposure to hazardous chemicals. EU decision-makers must seize this opportunity to set Europe on the road to a non-toxic and healthy future by improving REACH, the main piece of EU legislation on the use and marketing of chemical substances.

Dear Sir/Madam, in our view, the adaptation of REACH and CLP to the Green Deal is to be welcomed and overdue. The issue of safety data sheets and, above all, their quality is particularly important here. According to our experience, many safety data sheets — as they call uncertainty data sheets — are obsolete, incomplete, inconclusive, or even flawed.

Filed in German · English published by the European Commission

The revision of the REACH regulation is at the core of the interface of waste, chemicals, and products legislation. The interface is key to ensure the zero pollution ambition for a toxic free environment. The Reach regulation represents a significant cornerstone of the chemicals strategy for sustainability and an important piece of legislation to deliver the objective of the EU green deal.

Please find attached the contribution of Franceffat, BOCI, France clocks and UFBJOP, representatives of the French watches, jewellery, jewellery, goldsmiths and tableware sectors, on the Commission’s roadmap for the revision of the REACH Regulation.

Filed in French · English published by the European Commission

The European Space Industry, represented by ASD-EUROSPACE, would like to thank the European Commission for the opportunity to contribute to this important initiative for a targeted REACH Regulation revision from the very beginning.

EUROBAT welcomes the Commission Inception Impact Assessments for a revision of Regulation (EC) ‎‎No 1907/2006 of the European Parliament and of the Council concerning the ‎Registration, Evaluation, ‎Authorisation and Restriction of Chemicals (REACH).‎ ‎All battery technologies use substances that have hazardous properties. For instance, lead, cobalt, ‎nickel and cadmium are commonly included in batteries.

The aim "Burden reductions" is a main point, in particular for SMEs. Simplifying communication in the supply chain (digitalization, general common data base). Feralco supports the European Green Deal and the EU’s ambition to become climate neutral by 2050. We totally support the feedbacks by Cefic and VCI.

Thank you for this opportunity to provide feedback. This is provided in the attached PDF document. I was intending to also attach FPA Australia Guidance document for clarification, and an article from JOIFF Catalyst magazine, summarising major fire incidents where Fluorine Free foams and fluorinated foams were used, which shows some contrasting effects. It seems only a single file is permitted.

We would like to give following comments on the issues relating to articles. Please also see attached comments for details. (1) About “generic approach” and “grouping approach” – We believe that proper risk assessment needs to be kept as a fundamental scientific basis of chemical management. Grouping should be used only when the properties of substances are scientifically regarded as the same.

Please see the attached document for additional references A. Context and problem The Endocrine Society welcomes the proposal to revise the European Union (EU) legislation on registration, evaluation, authorization, and restriction of chemicals (REACH) to align legislation with the objectives of the Chemicals Strategy for Sustainability (CSS).

The Japan Chemical Industry Association (JCIA) welcomes the feedback opportunity regarding Inception Impact Assessment/Revision of CLP. The JCIA supports the noble ambitions of the EU’s Chemicals Strategy for Sustainability (CSS) which aims to improve the EU chemicals policy, including REACH and CLP, for sustainability and competitiveness.

Chemical legislation – Revision of the REACH Regulation and the Inception Impact Assessment Women Engage for a Common Future, WECF, welcomes the opportunity to comment on the revision of the REACH Regulation and the Inception Impact Assessment (IIA).

DI welcomes the possibility to submit our feedback. In general, DI - advices the Commission to strive for a coherent regulation of chemical risks across regulations and to avoid overlapping regulation for chemicals - acknowledges that REACH is the data generating regulation and supports the wish from the Commission to let data on e.g.

The NORMAN network (www.norman-network.net) is an independent, non-profit, multidisciplinary and multinational organisation in the field of CECs, which brings together more than 80 organisations in Europe, North America and Asia, representing various stakeholders such as competent authorities, reference laboratories established at the national level, research centres, academia and industry.

Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding Inception Impact Assessment/Revision of REACH. JBCE supports the objectives of the Chemicals Strategy for Sustainability are to better protect citizens and the environment against hazardous chemicals and encourage innovation for the development of safe and sustainable alternatives.

The Blood Transfusion Association (BTA), an international non-profit trade association committed to promoting the correct use and safe supply of blood for transfusion, welcomes the opportunity to provide feedback on the IIA of the REACH regulation. Over the years, blood supply has been hampered by population ageing, climate change, and more recently, COVID-19, due to the decrease in blood donations.

The Test & Measurement (T&M) Coalition was created in 2005 and represents an ad-hoc group of companies active in producing T&M industrial type products. Industrial monitoring and control equipment, including chemical analysers, are essential in the enforcement of and compliance with environmental legislation, and are a key driver of innovation.

As addressed within the European Green Deal we can make the EU´s economy more sustainable by turning climate and environmental challenges into opportunities. It is recognized that, to reach this target, actions by all sectors of our economy are required to innovate. Innovation and progress are coming with education, research, and autonomy.

Henkel welcomes the Commission’s commitment to ensure that the regulatory framework for chemicals reflects the objective to better combine health and environmental protection with increased global competitiveness and a strengthened internal market. However, an open discussion based on a holistic understanding of potential impacts on how this can be best achieved is needed before proposing legislative changes.

Cosmetics Europe is the trade association representing cosmetic and personal care product manufacturers in Europe. We support the objectives of innovation and a high level of protection of health and the environment, while preserving the free movement of products in the internal market and enhancing competitiveness of the industry.

Cefic welcomes the opportunity to provide first insights and suggestions for the REACH Revision Inception Impact Assessment public consultation. REACH is the most comprehensive regulatory framework securing safe use of chemicals. Recent European Commission’s reviews concluded that the system is fit for purpose, delivering on its objectives, and serves as a global model for chemical legislation.

Reach is the most comprehensive regulatory framework in place to ensure the safe use of chemicals. Recent European Commission reviews concluded that the system is fit for purpose, meets its objectives and serves as a model for third countries’ chemical legislation. From the chemical sector, we join these conclusions and commit to making REACH work.

Filed in Spanish · English published by the European Commission

The Deutsche Umwelthilfe e.V. (DUH) strongly supports the ambition in the Chemicals Strategy for Sustainability to introduce 1) endocrine disruptors, 2) persistent, mobile and toxic and 3) very persistent and very mobile substances as important categories of chemical substances of very high concern within REACH.

Eurocolour’s input to the inception impact assessment of the Revision of EU legislation on registration, evaluation, authorization and restriction of chemicals The EU’s REACH Regulation in combination with the CLP Regulation are unique in such a form and extent worldwide.

VdMi’s input to the inception impact assessment of the Revision of EU legislation on registration, evaluation, authorization and restriction of chemicals The EU’s REACH Regulation in combination with the CLP Regulation are unique in such a form and extent worldwide. The collection of information on the hazard and potential risks from chemi-cals is a huge gain for protecting human health as well as the environment.

The Fachverband Werkzeugindustrie e.V. represents around 150 manufacturers of tools and related products. The majority of enterprises are SMEs. Our member companies support REACh’s objectives, provided that their implementation does not put them at a competitive disadvantage compared to competitors based outside the EU.

Filed in German · English published by the European Commission

Chemical Industry Federation Finland appreciates the opportunity to comment the Inception impact assessment document. This consultation is very valuable, as proper impact assessment is the basis for any good regulatory process. We support the comments made by Cefic and would like to emphasize the following: The Chemical Strategy for sustainability proposes multiple changes to REACh and CLP regulations.

Orgalim, representing Europe’s technology industries, welcomes the revision of European Union legislation on registration, evaluation, authorisation and restriction of chemicals (REACH Regulation). Our technology industries, major downstream users and article manufacturers are fully committed to reducing the content of hazardous substances in their products to support a more circular economy.

ETRMA views on the Inception Impact Assessment on the revision of REACH Brussels, 28th of May 2021 Rubber is a versatile material flexible and resistant used for many applications. The industry producing rubber in Europe is organized in two main blocks. The most visible and known is Tyres present in vehicles.

The Microbial Control Executive Council (MCEC) welcomes the opportunity provided by the European Commission to submit views about the forthcoming revision of the EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH).

ALPLA is one of the leading companies involved in plastic packaging. Around 21,600 employees worldwide produce custom-made packaging systems, bottles, caps and moulded parts at 178 sites across 45 countries. REACH is a necessary measure to protect human health and to minimize environmental contamination. REACH Authorisation is however known to be challenging especially for SMEs in terms of the application cost.

The Health and Environment Alliance (HEAL) welcomes the opportunity to comment on the inception impact assessment for the revision of the REACH legislation. We support the Commission’s assessment of the state of the legislation.

The European Precious Metals Federation (EPMF) supports the ambition of the European Green Deal and the objectives of the Chemicals Strategy for Sustainability. To achieve them, a targeted revision of the REACH Regulation was launched, focusing on the main problems identified during the last evaluation of REACH in 2018.

Huntsman supports a targeted reopening of REACH to make the Regulation more efficient in protecting human health and the environment while enabling the sustainable innovations needed to meet the ambitions of the European Green Deal. Huntsman has invested significantly in REACH in line with our support for sound regulation of chemicals based on robust science.

essenscia welcomes the opportunity to participate in the public consultation on the inception assessment on REACH. essenscia and its members support the comments submitted by Cefic in this consultation. Additionally, we want to highlight some points.

The Polish Association of Cosmetics and Detergent Industries (PSPKD) supports the political commitments made in the framework of the CSS. However, decision-making processes for the revision of REACH should not be speeded up, but should be dealt with properly, in line with the Better Regulation principles. The results of the second REACH review show that the Regulation fulfils its objectives and tasks.

Filed in Polish · English published by the European Commission

The European Melamine Producers Association (EMPA) welcomes the opportunity provided by the European Commission to share views regarding the revision of the REACH Regulation, expected for Q4 2022. With the publication of the Chemicals Strategy for Sustainability in October 2020, the European Commission proposed many actions to review and update the current policy framework on chemicals.

IndustriAll European Trade Union is a federation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and activities. We speak for 7 million working men and women united within 180 national trade union affiliates in 38 European countries.

B. OBJECTIVES AND POLICY OPTIONS Simplifying communication in the supply chains COMMENT Division 4 of BAuA As identified in the last REACH review the communication in the supply chain is inefficient. Without tackling this inefficiency it won't be possible to fulfil the aims of the Chemicals Strategy for Sustainability, because all actions rely on a functioning communication system.

We appreciate the opportunity to provide feedback for improvement of REACH regulation. One of our concerns is administrative workload that is needed to comply with REACH. It would be appreciated if the future work on the regulation would take that into account. More administrative work that REACH demands increases costs and may cause delayed implementation of the legislation.

EFPIA, the research-based pharmaceutical industry, supports the Commission’s objective to revise, improve and simplify the REACH regulation. We welcome the opportunity to be recognised as a key stakeholder to develop and implement better chemical regulations.

We welcome the possibility to provide input to the Inception Impact Assessment on the revision of the REACH Regulation. LANXESS supports the Green Deal goals of the European Commission. Sustainability plays a crucial role in the corporate strategy of LANXESS. We, therefore welcome the fact that the European Commission puts a strong focus on sustainability in its future chemicals policy.

It is important that the CLP Regulation is clear and unambiguous in terms of risk identification, classification and the responsibilities of different actors. It is important to expand the area where CLP applies if necessary to reduce risks to human health and the environment. It is not wrong to open up before a completely new group, eg endocrine disruptors, if this is justified.

• ÖVGW welcomes the zero-pollution action plan as part of the European Green Deal together with the Chemicals Strategy for Sustainability for a toxic free environment with the aim to better protect the environment – including drinking water resources - against hazardous chemicals.

DUCC members are highly committed to successfully implement REACH which has been one of the most important regulations to ensure consumers and products safety in Europe on chemical risks. However, DUCC is of the opinion that any future actions to be taken should preferably involve using and strengthening existing tools as the set goals could be achieved by securing an overall better implementation of REACH…

The Swedish Government welcomes the opportunity to comment on the upcoming review on the REACH Regulation. The review of the REACH Regulation offers a possibility to further strengthen the protection of human health and the environment while at the same time providing a level playing field for the European industry. See attached file for comments

The German Paint and Printing Inks Industry Association (VdL) is grateful for the opportunity to comment on the planned measures as part of this consultation.Our industry depends on a broad raw material portfolio to ensure the effectiveness of the various products of the coatings and printing industries and will be bound by the plateed measures. Please find attached our comments.

Filed in German · English published by the European Commission

The International Fragrance Association welcomes the opportunity to comment on the EU Commission Inception Impact Assessment on REACH. Full comments are available in the attachment. The revision of the REACH regulation should be targeted and science based. The Commission should seek to build on the current solid and existing framework to make it more efficient, consistent and streamlined.

BV Glas supports the goal of the Commission to better protect citizens and the environment against hazardous chemicals and encourage innovation and believes that its products are aligned with these criteria. However, in the revision of the REACH Regulation, considerable tightening of the regulations is planned. BV Glas would like to contribute to the REACH revision process.

Biopharmachem Ireland supports the Commission’s objective to revise, to improve and to simplify the REACH regulation. The biopharmachem sector is highly regulated under medicinal legislation and complies with existing community legislation that adequately protects workers, consumers, and the environment.

On behalf of the Biogeochemistry and Ecotoxicology unit, we strongly support the ambition in the Chemicals Strategy for Sustainability to "introduce endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern" within REACH. In addition, we support initiatives to make chemical data public and widely usable.

We strongly support the planned amendments to Regulation (EC) No 1907/2006 on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) in order to fill knowledge gaps, simplify legislation and improve communication. A comprehensive assessment of hazardous substances, a risk-benefit assessment and, ultimately, their authorisation or restriction is possible only after extensive testing.

Filed in German · English published by the European Commission

CIHEF represents the French Essential oil sector of lavandin, lavender and clary sage. Its members are plant growers/farmers of lavandin, lavender and clary sage plants, distilleries, and cooperatives of essential oils as well as companies, which buy essential oils directly to a farmer or a cooperative. Its members are mainly micro and small enterprises (SMEs).

• We strongly support the ambition in the Chemicals Strategy for Sustainability to "introduce endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern" within REACH.

EUROMOT (the European Association of Internal Combustion Engine Manufacturers) appreciates the opportunity to comment on the EU Commission’s Inception Impact Assessment (IIA) on the REACH revision. EUROMOT supports the Commission’s intention to step up action in the chemicals area in order to protect citizens’ health, as well as to simplify EU legislation on chemicals and make it more effective.

SK CA appreciate that the Commission provided more concrete proposals concerning REACH (& CLP) targeted revisions in relation to the actions arising from Chemicals Strategy for Sustainability. We welcome the idea of the simplification and strengthening of the legal framework for regulation of chemicals by establishing a simpler 'one substance - one assessment' approach for the hazard and risk assessment of…

Fecc acknowledges the inception impact assessment on REACH under the objectives of the Chemical Strategy for Sustainability (CSS). In this context we would like to raise the following points on behalf of the European chemical distribution sector, above all on behalf of the many SMEs we represent: 1. Environmental footprint information should consider an enforceable safety scheme.

We welcome the opportunity offered by the European Commission to express our expectations regarding the revision of the REACH Regulation. According to our organisation, it needs to be strengthened and thoroughly revised. This is why we support the simplification, revision and reform actions set out in the Roadmap.

Filed in French · English published by the European Commission

We welcome a careful and limited revision of the EU legislation on registration, evaluation, authorisation and restriction of chemicals, REACH, to better protect humans and the environment against hazardous chemicals and promote a sustainable use of chemicals. It is key, however, that a revision does not lead to a weakened chemicals regulation, in any aspect.

In order to further improve the REACH Regulation and to make it a valuable tool in implementing the Green Deal objectives in creating a non-toxic environment, it is essential for market surveillance authorities to work consistently to improve the compliance of registration dossiers. Reviews have shown that only one third of registration dossiers fully comply with the information requirements.

Filed in German · English published by the European Commission

The VCH thanked the European Commission for the opportunity to comment on the planned REACH revision. VCH thanks the EU Commission for the openness to comment on the propsed REACH Revision. Please find our opinion in PDF format. Our feedback can be found as per pdf file attached.

Filed in German · English published by the European Commission

The revision of REACH should aim at meeting the ambitions in the Green Deal and the Circular Economy Action Plan. To bridge the gap between the waste legislation and the chemicals legislation, this revision need much more focus on recovered substance to be able to facilitate a Circular Economy. In particular, the application of REACH art. 2(7) “recovered” substances needs to be clarified.

A different methodological framework for the application for authorization should be allowed, whereby the applicants would be allowed to compare different waste management options for the waste containing the substances in question under the analysis of alternatives. The substitution plan could feature aspects such as the development of technology to remove the substance from the input material.

We strongly support the ambition in the Chemicals Strategy for Sustainability to "introduce endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern" within REACH.

ecopa is the European consensus-platform for alternatives. The primary aim of ecopa is to promote “the three Rs” (Replacement, Reduction and Refinement) in the use of animals in research, testing, education and training in Europe.

Environmentalists in Action appreciate the opportunity offered by the European Commission to express our views and to point out our proposals regarding the review of the REACH Regulation. In our organisation’s view, this regulation should be thoroughly revised in order to make possible the commitments of the Green Deal, the Chemicals Sustainability Strategy, the Zero Pollution Action Plan, the EU Plan to Combat…

Filed in Spanish · English published by the European Commission

Summary The aerospace industry supports the objectives of REACH, in particular the principle of better protecting citizens and the environment from hazardous chemicals. We are keen to participate constructively in the revision of the legislation. Such a revision should address the identified shortcomings in a targeted and efficient way, based on a sound impact assessment.

In the name of the research groups involved in assessment of chemical risks at the University of Antwerp (Belgium), we strongly support the ambition in the Chemicals Strategy for Sustainability to introduce 1) endocrine disruptors, 2) persistent, mobile and toxic and 3) very persistent and very mobile substances as important categories of chemical substances of very high concern within REACH.

FEICA would appreciate the consideration of the following issues with respect to the impact of the revision of REACH on adhesives and sealants formulators. Revision of registration requirements The use of polymers within the adhesives and sealants industry is very widespread.

ERM Coalition of drinking water supply associations represents the interest of 188 million people in the river basins of Rhine (IAWR, AWBR, ARW, RIWA-Rijn) and Ruhr (AWWR), Danube (IAWD), Elbe (AWE), Meuse (RIWA-Meuse) and Scheldt (RIWA-Scheldt) in clean drinking water.

EurEau is the European association of water service providers with 34 national member organisations in 29 countries. ~ Drinking water suppliers have been raising concerns about persistent, mobile and toxic (PMT) and very persistent, very mobile (vPvM) substances as they can still be detected decades after their withdrawal from the market.

ESPP welcomes the objectives of revising REACH towards Green Deal ambitions but regrets that the Circular Economy is not addressed. In particular, the application of REACH art. 2(7) “recovered” substances needs to be clarified.

Our industry depends on a broad raw material portfolio to ensure the functionality of the diverse products of the coatings and printing inks industry and is therefore concerned about the proposed development, which may lead to the disappearence of key chemistries simply based on hazard and not on risk. Please find attached our comments.

We thank the European Commission for the possibility to provide inputs to the roadmap consultation regarding the revision of REACH Regulation to help achieve a toxic-free environment as a crucial next step in successfully delivering on the objectives of the Chemicals Strategy for Sustainability (CSS).

The Center for International Environmental Law (CIEL) welcomes the opportunity to provide feedback on the revision of the REACH Regulation and the Inception Impact Assessment (IIA). We welcome the ambitious commitments established in the Chemicals Strategy for Sustainability (CSS) and call on the Commission to ensure the implementation of all the promised actions.

Picon is a leading industry trade association representing manufacturers and suppliers to the Printing, Papermaking and Paper Converting sectors and welcomes the opportunity to respond to this Inception Impact Assessment (IIA) on the planned revision to Regulation (EC) No. 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals, the REACH Regulation.

CHEM Trust welcomes this opportunity to input into the Commission’s discussions on the revision of the EU’s crucial REACH chemicals regulation. CHEM Trust is an NGO that focusses on EU-level regulation of chemicals, in particular endocrine disrupters and persistent, bioaccumulative and/or mobile chemicals.

The Cobalt Institute represents over 75% of global cobalt production and processing. It is a non-profit trade association composed of producers, users, recyclers, and traders of cobalt. We promote the sustainable and responsible production and use of cobalt in all its forms.

Implementation of laws and regulations has to be assessed differently in the EU Member States. First, uniform enforcement must be established before laws and regulations are strengthened or expanded. Otherwise, there is a distortion of competition which bans further regulatory initiatives and is contrary to the EU internal market article.

Filed in German · English published by the European Commission

We strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of PMT and vPvM as new hazard classes.

As a Polish competent authority for REACH and CLP regulations, Bureau for Chemical Substances would like to share our concerns and advise against reforming the authorisation process by introducing national authorisation for smaller applications. We believe that such an initiative is likely to negatively impact the functioning of the single market for chemicals in the EU.

The ZVO welcomes the opportunity to publicly comment on the EU Commission's plans for the revision of REACh. In this context, the ZVO expressly supports the objectives of sustainability and protection of human health and the environment on which the paper is based. However, the ZVO urges that all measures must be demonstrably effective as well as economically, socially and technologically acceptable and feasible.

APPLiA, representing EU manufacturers of home-appliances, including large domestic appliances, small domestic appliances and heating, ventilation, and air conditioning (HVAC) equipment, would like to provide the European Commission with the views of the sector and further recommendations regarding the objectives and policy options as proposed in the IIA called “Revision of EU legislation on registration, evaluation…

The European Federation for Construction Chemicals (EFCC) represents European construction chemicals companies and national member associations, representing raw materials producers and formulators of finished products, including SMEs, across the European Union. EFCC welcomes the opportunity to participate in the public consultation on the Inception Impact Assessment for REACH.

I strongly support the aim of the Chemicals Strategy for Sustainability to achieve zero pollution. The following substances are to be included in REACH: ‘Endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern’. Zero pollution of the environment should be pursued. Toxic substances shall be replaced by non-toxic substances.

Filed in German · English published by the European Commission

As part of the CSS, the European Commission has proposed a large number of very ambitious measures to adapt EU chemicals legislation. The implementation of these would have far-reaching consequences for European industry. In particular, significant improvements are foreseen in the adaptation of the REACH Regulation.

Filed in German · English published by the European Commission

CropLife Europe (CLE) welcomes the opportunity to provide feedback and wishes to make the following comments: Part A REACH is the most advanced knowledge base globally but there are still gaps in knowledge on many substances: A retrospective review by the US Environmental Protection Agency in 2013 (“A retrospective analysis of immunotoxicity studies”, February 2013, Health Effects Division, OPP, US EPA), was…

The EU Chemicals Strategy intends large numbers of amendments and extensions of the existing chemicals legislation. These will have major impacts on both the chemical industry and users of chemicals (substances, mixtures and articles).

The EU has a robust framework for regulation of chemicals, which is the most comprehensive in the world. There are REACH and CLP Regulations and 40+ pieces of EU chemicals legislation, that strictly regulate management of chemicals. The result of implementation of the REACH Regulation is the largest database of information on chemical substances in the world.

PL (Ministry of Economic Development, Labour and Technology) welcomes upcoming changes to the REACH regulation, and our main comment is not to rush decision-making processes. Any initiative shall be conducted with regards to the principles of Better Regulation, sound science and cooperation with relevant stakeholders.

The REACH revision offers the opportunity to create a coherent REACH framework balancing the objectives of the Sustainable Chemicals strategy and the EU strategic autonomy agenda. Use cases in which chemical substances are needed for strategic value chains and used safely in controlled environments must be excluded from authorisation requirements as well as from blanket restrictions to not risk further increasing…

I strongly support the ambition in the Chemicals Strategy for Sustainability to "propose new hazard classes and criteria in the CLP Regulation to fully address environmental toxicity, persistency, mobility and bioaccumulation", by inclusion of Persistent, Mobile and Toxic, including very Persistent and very Mobile substances as new hazard classes.

The current procedures for registration & authorisation are a heavy burden for EU competitiveness. The current procedures for evaluation of registration dossiers and substances are complex, costly and take too long. The authorisation procedure is too heavy and inflexible. The authorisation process has imposed a heavy burden on both companies and authorities.

ECFIA (representing the high temperature insulating wool manufacturers) welcomes a review of the REACH regulation and is encouraged to see that the commission recognises and wishes to resolve some weakness, especially in relation to authorisation and restriction.

According to Wirtschaftsvereinigung Stahl, REACH is an important tool to improve chemical safety. By 2010, the German and European steel industry had already registered most of the substances it placed on the market or imported. The information submitted in the context of the registration allows for a better assessment of the properties of the substances than was the case before the entry into force of REACH.

Filed in German · English published by the European Commission

The revision of REACH should be an opportunity to move towards the end of animal toxicity testing. In addition to being ineffective in assessing the danger to human health and the environment, these tests have already condemned millions of animals to particularly painful cruel experiments.

Filed in French · English published by the European Commission

Bioconcentrate BV is the producer of microbiological cleaners against testing on animals. Technologies have now been developed within the cleaning world in which animal testing no longer has a place. Our company does not use ingredients that have been tested on animals and our products show that it is possible to clean naturally at any level. Both at home and in industry. We oppose testing on animals.

Filed in Dutch · English published by the European Commission

Deutsche Bauchemie (DBC) supports the Green Deal goals as well as the transition towards a more sustainable society. Construction chemical products are decisive: Modern concrete admixtures reduce the amount of cement used in concrete and thus contribute to the reduction of CO2-emissions. Sealants ensure the airtightness of buildings and help save energy.

The REACH Regulation sometimes does not allow companies to find solutions to their questions because it is unclear, it is not easy for companies to find references and leaves them with doubts as to their interpretation. For example, the fact that they must subsequently be able to fully substantiate and document their assessments and the conclusions reached by panic.

Filed in Italian · English published by the European Commission

Hubergroup, an European printing inks and chemicals manufacturer with a global presence, welcomes the opportunity to comments on the REACH revision inception impact assessment. We fundamentally agree on the main objectives included in the Chemicals strategy for sustainability (CSS), although we are concerned with the method of implementation and the speed of the action proposed.

I strongly support the ambition in the Chemicals Strategy for Sustainability to "introduce endocrine disruptors, persistent, mobile and toxic and very persistent and very mobile substances as categories of substances of very high concern" within REACH.

I am pleased with such a large participation in this important public consultation on REACh. 10 years ago in the various surveys, the comments could be counted on the fingers of one hand, we were very few. I do not know how much the Commission will value our comments, which I want to clarify are not complaints, but serious analyzes and possible solutions. Thanks to everyone we continue to have our say!

The CETS lists its key conclusions here, detailed justifications for the conclusions can be found in the attached document Key Comments: - A toxic-free environment is a fantasy as there are many naturally occurring toxic organisms and substance in the environment already. CETS considers it questionable to establish such an approach as a basis for decision-making.

We believe that the REACH revision must go hand in hand with a change in the concepts with which chemicals are valued. We regret that, at present, the assessments are mainly based on the ‘hazard’ which substances could represent and not on ‘risk’.

Filed in French · English published by the European Commission

The EU needs a general simplification of its chemicals legislation and a chemicals policy, which is more inclusive for SMEs. The Commission should give high priority to this aspect during the evaluation of the REACH Regulation. In more detail SMEunited suggests: It should be explored, how to further exploit the obligatory data/cost sharing to reduce burden.

Reach currently has two weaknesses: 1- New molecules produced in small quantities are not the subject of an application for a marketing authorisation and a study on their possible toxicity. However, these new molecules, which are created in large numbers each year, necessarily have a cumulative impact on health and the environment.

Filed in French · English published by the European Commission

The latest REACh update of 2018 concluded that it is effective but that there are opportunities for further improvement, simplification and burden reduction. On the reduction of burdens, we have already said countlessly that it is not these actions that make the registration process sustainable, but the SIMPLIFICATION must be done and not just with words. A simplification / improvement would be a check on the SIEFs.

On the contrary, the chemicals strategy for sustainability and the resulting legislation should put an end to animal experimentors to ‘prove’ their unscientific methodology that all these toxins are suitable for use. Animal experiments are unreliable and unscientific, as well as cruel. Animal test-takers told us that tobacco would be safe, just like asbestos and Chrome-X.

Filed in Dutch · English published by the European Commission

Communication in the supply chain: The current system should become more efficient. The interface with worker protection needs to be improved. The quality and availability of SGMs has improved significantly in recent years. We therefore do not see a need for more information, but rather simplification. Authorisation: This is a major challenge for our businesses.

Filed in German · English published by the European Commission

The commitment to the Green Deal must not be a European exclusive, otherwise we would only harm our economy and industry. The competent authorities must absolutely dialogue with the Asian ones, due to their not very green and safe vision when they export goods, unlike when they import them, where they are very careful. It cannot always pay the EU industry, especially SMEs.

The chemicals strategy and the legislation it generates must be an opportunity to finally move away from the cruel, outdated and unreliable dependence on animal testing in the European Union — something that is overwhelmingly supported by European citizens and is also necessary if we want to take truly sustainable steps.

Filed in Dutch · English published by the European Commission

Buongiorno, starting with the summary < < The European Green Deal sets the objective of zero pollution for a toxic-free environment. > >. We are again making the mistake not to distinguish PERICOLO from RISK. Toxic/hazardous substances will always exist. It is the risk that needs to be managed to minimise the hazard.

Filed in Italian · English published by the European Commission

We, ADDA, as the oldest NGO in Catalonia and Spain in the defense of animals and nature, are very concerned with the proposals of the new text of the Chemicals Strategy for Sustainability for the omission that is made, again, of a key concept: the respect for animals, which is also respect for the environment and nature.

I have read your objective of achieving zero use of chemicals in agriculture and I have been honestly perplexed: How do you plan to succeed in feeding an ever-growing world population by so much reducing the use of chemistry (including fertilisers)?

Filed in Italian · English published by the European Commission