Hubergroup would like to comment on to the proposed revision of the CLP Regulation, and the documents published on 19th December 2022: Minimum Requirements for Labels (OLP text p43. Annex I para (2)) We are very concerned that labels are increasingly difficult to read as a result of additional information requirements (often due to substance reclassifications).
HDG
hubergroup Deutschland GmbH
Company · Germany
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.
4
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
3
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.
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Their record over time
hubergroup Deutschland GmbH filed 4 positions between 1 Feb 2019 and 10 Feb 2023, across 3 of the 665 legislative files tracked here, attaching a full position paper 3 times.
2019 · 1 filed2021 · 2 filed2023 · 1 filed
What they argued
Hubergroup, an European printing inks and chemicals manufacturer with a global presence, welcomes the opportunity to comments on the CLP revision inception impact assessment. We fundamentally agree on the main objectives included in the Chemicals strategy for sustainability (CSS), although we are concerned with the method of implementation and the speed of the action proposed.
The hubergroup produces inks for a wide range of applications. A very large number of our products contain titanium dioxide. Therefore, the planned classification would have far-reaching consequences for our group of companies.
Filed in German · English published by the European Commission
Hubergroup, an European printing inks and chemicals manufacturer with a global presence, welcomes the opportunity to comments on the REACH revision inception impact assessment. We fundamentally agree on the main objectives included in the Chemicals strategy for sustainability (CSS), although we are concerned with the method of implementation and the speed of the action proposed.
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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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