Japan Chemical Industry Association (JCIA) appreciates the opportunity to provide the following comments in response to the proposal of amending CLP regulation. JCIA supports the EU's efforts to strengthen the Chemicals Management under the Chemicals Strategy for Sustainability (CSS).
Japan Chemical Industry Association
Industry association · Japan · EU Transparency Register 574906315390-52
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.
Who they are
Among the 1519 trade and business associations on this site, they rank #553 by legislative files engaged, a count of participation, not a measure of influence.
Declares membership of
- JCIA is a member of the International Council of Chemical Associations (ICCA).
- https://icca-chem.org/
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026).
- Register category
- Trade and business associations
- Head office
- Chuo-ku, Tokyo, Japan
Self-declared to the EU Transparency Register (snapshot 15 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Japan Chemical Industry Association filed 7 positions between 1 Jun 2021 and 15 Sept 2026, across 6 of the 665 legislative files tracked here, attaching a full position paper 4 times.
What they argued
The Japan Chemical Industry Association (JCIA) welcomes the feedback opportunity regarding Inception Impact Assessment/Revision of CLP. The JCIA supports the noble ambitions of the EU’s Chemicals Strategy for Sustainability (CSS) which aims to improve the EU chemicals policy, including REACH and CLP, for sustainability and competitiveness.
The Japan Chemical Industry Association (JCIA) welcomes the feedback opportunity regarding Inception Impact Assessment/Revision of CLP. The JCIA supports the noble ambitions of the EU’s Chemicals Strategy for Sustainability (CSS) which aims to improve the EU chemicals policy, including REACH and CLP, for sustainability and competitiveness.
We support the development of effective sustainability criteria that contribute to the PPWR's circular-economy objectives and facilitate the uptake of high-quality recycled materials. Sustainability criteria for plastic recycling technologies should be outcome-based and technology-neutral.
We support the development of a clear, practical and verifiable methodology for calculating and verifying recycled content that can be applied consistently throughout the EU. The methodology should be consistent with the basic calculation framework under Article 7(1) and (2) of the PPWR, including calculation per packaging type and format as an average per manufacturing plant and year.
We support the establishment of a robust framework that safeguards the credibility of the PPWR recycled-content targets while enabling high-quality recycled materials produced both within and outside the EU to contribute to the circular economy under fair conditions.
Japan Chemical Industry Association (JCIA) appreciates the opportunity to provide the following comments in response to the proposal. JCIA respects the ambition of the European Chemicals Strategy for sustainability, which calls for the safe management of chemicals.
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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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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.