CLP Regulation is first of all the implementation of the GHS. Therefore, it is very important for CLP to strictly follow the GHS. Adding new hazards category is helpful only if those are included in GHS, in order to avoid confusion during circulation of chemicals across countries. Additional information is included in the eSDSs as requested for REACH regulation.
ecopa
NGO · Belgium · EU Transparency Register 592558413934-02not in register snapshot
This register number is the organization’s own declaration on its submission. It is not in the 14 Oct 2026 snapshot of the EU Transparency Register, so we neither link to it nor use it to identify this organization.
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
ecopa filed 7 positions between 31 May 2021 and 15 Mar 2025, across 7 of the 665 legislative files tracked here, attaching a full position paper 2 times.
What they argued
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.
This submission addresses key considerations for the evaluation of the Cosmetic Products Regulation (CPR), focusing on its effectiveness, relevance, coherence, and EU added value. The revision presents a crucial opportunity to align the regulation with scientific advancements, public expectations, and ethical principles while ensuring consumer and environmental protection. Key Considerations: 1.
This initiative is remarkable. Just one comment about:"create a data-generation mechanism for EU and national authorities and oblige industry and (external) testing laboratories to notify these authorities of any studies they commission, based on existing notification rules in the food sector.". This obligation has a negative impact on basic research about NAMs (New Approach Methodologies).
This initiative is positive as having a more efficient harmonization among the EU agencies, with optimization of resources and expertise is important. Just a couple of issues: 1. It is not clear why the fitness check of all chemicals legislation should exclude REACH which is THE chemical legislation by definition 2.
Revision of the cosmetic product regulation is welcome, with the aim to increase protection of human health and the environment. Attribution to ECHA of the SCCS tasks can lead to a more efficient management of the cosmetic product control. However, this should not fade the principle from which no new animal tests should be performed for safety assessment of both cosmetic products and ingredients.
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).
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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