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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

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 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.

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!

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.

It must be precise and standardised without leaving room for interpretation, as is the case for certain aspects of the textile/fashion world, one of which has been confused with azo dyes. Here, apart from the REACh Regulation, which explains it very well, many NGOs that are unreliable, but with great media resonance, have always used the term azotic or azo as a synonym of a serious danger to health.

Filed in Italian · English published by the European Commission

Plastics Recyclers Europe, the association representing the plastic recycling industry at the EU level, welcomes the ECs initiative to revise the EU textile labelling rules, as an opportunity to introduce requirements on communicating on the environmental aspects of textiles, in line with the objectives of the EU Textiles Strategy. Please find attached our feedback to the public consultation.