not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
8
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Good staff, I am writing in Italian to avoid misunderstandings due to my bad English regarding the draft published by the European Commission on the revision of CLP Regulation, Brussels, 19.12.2022 COM (2022) 748 final 2022/0432 (COD). I am Maurizio Ronchi, a chemical in Gammacolor, a small SME that imports and markets colorants for the textile/fashion sector.
Filed in Italian · English published by the European Commission
Another aspect, it is scandalous that those who export to the EU are allowed to fail to provide the least cooperation to those who care. I am referring to the NON-classifications that Asian manufacturers continue to maintain on their products. The Commission must, indeed already had to, ensure that the competent authorities of the EU and of the exporting countries of chemicals dialogue.
the GHS exists as a global harmonized system, I don't understand why the EU with CLP would like to introduce other risk categories, disharmonizing a project that finally wants to unify the classifications. But why did the Commission stick to the "most ambitious chemicals regulation in the world", but are you aware of the damage you already do to industry and especially to SMEs?
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!
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.
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.
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
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
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