ChemSec

Unknown or toxic chemical content in recycled material is a main hurdle for increased use in products. While many companies have very high ambitions to increase this use, the material available is often not meeting their standards that are in place to ensure safety.

ChemSec welcomes the proposal from the Commission on Green claims. If the legislation is to be useful and trustworthy there are two elements that need to be fulfilled; the information on green claims must be both truthful and actually beneficial for the environment.

ChemSec supports the Commissions ambition to address the prerequisites of producing sustainable products, in line with the Green Deal, the Circular Economy Action Plan and the Chemical Strategy. ChemSec is positive towards widening of the ecodesign directive beyond energy related products and the establishment of overarching product sustainability principles.To achieve useful and relevant principles it is essential…

ChemSec welcomes the Commissions proposal for a revision of the CLP Regulation. We share the aim of modernising and streamlining the regulation to make it more efficient and protective. However, we have some important recommendations to improve safety for consumers and the environment. We strongly supported the delegated act to include EDCs, PBTs, vPvBs, PMTs and vPvMs as new hazard classes.

ChemSec welcomes the proposed changes and additions to the CLP regulation, as laid out in the Chemicals Strategy. We fully support the aim to urgently achieve a better protection of human health and the environment through more efficient identification, labelling and communication on hazardous chemicals.

General Remarks This is the third revision of Appendix C in four years. Each revision creates additional administrative burden, forces practitioners to re-examine and re-report, and generates confusion across the market. This is the opposite of simplification and good governance, and it erodes trust in the Taxonomy as a stable and reliable framework. The direction of travel is also wrong.

ChemSec welcomes the opportunity to respond to this consultation on the roadmap for the Revision of EU rules on food contact materials (FCMs). We recognize and appreciate that the Commission in its roadmap identify a number of troubling issues that we believe urgently needs to be addressed. The most striking issue is that there is currently not a coherent system for regulation of substances of concern.

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 delegated act on recycled content in PET includes elements that cause great concern for the level playing field, credibility and innovation regarding recycling of all plastics in the future. This delegated act may serve as a blueprint for other legislation and is therefore very worrying.

ChemSec comments on the proposal for a directive concerning urban wastewater treatment (COM(2022) 541 final) ChemSec welcomes the EU Commission's proposal for a revised urban wastewater treatment directive (UWWTD) and would just like to raise one important point in this consultation- the need to include the removal of PFAS in the advanced treatment requirements.

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

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

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

We welcome the revision of the Cosmetic Products Regulation and the proposed way forward presented in the roadmap. In our view the roadmap cover all necessary issues to be revised to make sure the Cosmetics regulation is in line with the aims and ambitions of the Chemical Strategy.

ChemSec thanks the Commission for the opportunity to leave comments to the Inception Impact Assessment on the simplification and digitalization of labels on chemicals. ChemSec agrees with the general idea of creating a harmonized digital labeling system for chemical product information.

ChemSec welcomes the work the Commission is conducting on Circular Economy. However, we sense through the number of consultations and events that the important perspective of the progressive down stream users as well as the recyclers have not been given the appropriate space. Increasingly, downstream users are realising that hazardous substances mean exposing customers to a risk.

ChemSec welcomes and supports in general the proposed restriction of CMR substances in childcare articles. We urge the REACH Committee to conclude swiftly and the Commission to adopt the restriction as soon as possible. We support the dynamic link to CLP which makes the restriction effective, preventative and forward looking.