CEPE

CEPE has provided its input to the European Commissions initiative on national registers of producers under the Packaging and Packaging Waste Regulation. The submission sets out the sectors views on how producer registration requirements should be implemented in a consistent, efficient and proportionate way across the EU, while minimising unnecessary administrative burdens for companies.

CEPE Feedback on the Call for Evidence – Circular Economy Act 06-11-2025 The European Council of the Paint, Printing Ink, and Artists’ Colours Industry (CEPE) welcomes the European Commission’s initiative to accelerate the transition to a circular economy through the forthcoming Circular Economy Act (CEA). CEPE recognises the importance of resource efficiency, decarbonisation, and reducing environmental impacts.

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

CEPE contribution to EU consultation Review of the requirements for packaging and other measures to prevent packaging waste CEPE, in principal, supports any meaningful initiative aimed at preventing packaging waste.

(Please see the attachment for the full statement) CEPE welcomes the initiative for a European Critical Raw Materials Act. Chemicals are key for the well- functioning of various strategic supply chains and should therefore be considered in the act1. CEPE reminds of the severe raw material shortages that started in 20212 and the continued high prices impacting the sector in its ability to supply.

CEPE contribution on the roadmap for a Legislative proposal on substantiating green claims CEPE welcomes the opportunity to comment on the European Commission's roadmap for a legislative proposal on substantiating green claims. The paint, printing ink and artists' colours manufacturers are committed to working towards greater sustainability and gladly share their experience and expertise in light of this initiative.

CEPE welcomes the opportunity to comment on the adopted Ecodesign for Sustainable Product Regulation (ESPR) proposal. CEPE finds the following elements to be critical for its industry sectors. • CEPE finds the ESPR proposal a tool for ensuring a level-playing field for certain product categories.

With regard to the revision to the CLP Regulation, and the documents published on 19th December 2022, CEPE would like to share the following initial comments from our members on three important topics: Minimum Requirements for Labels (OLP text p43.

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.

CEPE welcome this public consultation under the Better Regulation initiative. CEPE represents the paint, printing ink and artists’ colours manufacturers in Europe. Our industry is the main user (60% of total volume) of the essential pigment titanium dioxide.

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.

CEPE inputs address the proposed sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation. The inputs are intended to provide technical and sector-specific considerations for the development and assessment of the harmonisation of rules for calculating and verifying recycled content in plastic packaging.

CEPE would like to identify two key areas where administrative burden could be reduced without affecting the legislative objectives. 1) Poison center notification under CLP (Regulation 1272 2008): the level of details required is going beyond what is strictly necessary for medical treatment in case of poisoning incident (mostly symptomatic treatment).

CEPE, The European Council of the Paint, Printing Ink and Artists' Colours Industry, welcomes the opportunity to contribute to the call for evidence on the BPR. The EU paints and inks industry encounters significant difficulties and concerns with this very complex biocide legislation, and we believe that, in its current form, it is not fit-for-purpose. Please find attached our contribution.

CEPE believes that a better use of resources and avoidance of duplication of work could be done but only for the derivation of hazard endpoints. With regard to the open data platform on chemicals, the repository of health-based limit values, or tools to improve access and uptake of academic data in regulatory work, CEPE would like to stress the importance of maintaining a high level of scrutiny on the quality of the…

CEPE, The European Council of the Paint, Printing Ink and Artists' Colours Industry would like to submit its inputs to the Commission as part of the consultation on the disclosure of information on unsold consumer products.

CEPE welcomes the opportunity to provide some initial thoughts on the Inception Impact Assessment (IIA) launched by the European Commission (EC) in July 2021. Role of the label One common denominator amongst all chemical products sold in the EU is that they have a label attached to them.