The European Phenolic Foam Association (EPRA) fully supports the broad objectives of the Eco-Design for Sustainable Products Regulation (ESPR), but is concerned that the inclusion of the full list of Substances of Concern from the outset could put the regulation out of step with the implementation of the Chemical Strategy for Sustainability (CSS) and potentially force substitutions which are neither sustainable nor…
EPF
European Phenolic Foam Association (EPFA)
Industry association · United Kingdom
2
positions filed
in the 639 files tracked
2
legislative files
of 639 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 639 consultation files tracked so far (53,766 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
European Phenolic Foam Association (EPFA) filed 2 positions between 22 Jun 2022 and 23 Jun 2022, across 2 of the 639 legislative files tracked here.
What they argued
The European Phenolic Foam Association (EPFA) would like to submit the following comments on the proposed Regulation on Substances that Deplete the Ozone Layer. They refer specifically to Article 20 of the draft and notably subparagraphs 2, 3 & 4 which relate to the management of insulation foam products at renovation, refurbishment or demolition.
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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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