As a horizontal piece of legislation, CLP has a wide-ranging impact, with any change likely to have a knock-on effect on various sectors, including but not limited to biocides, pesticides, detergents, cosmetics, toys, and medical devices. For example, CLP Self-classification of substances is being included in horizontal regulations to trigger requirements without an assessment of impacts (e.g.
DUC
The Downstream Users of Chemicals Co-ordination group (DUCC)
Industry association · Belgium · EU Transparency Register 70941697936-72
8
positions filed
in the 665 files tracked
6
legislative files
of 665 tracked
6
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 (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #520 by legislative files engaged, a count of participation, not a measure of influence.
1
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
0
EP accreditations
as declared to the register
2012
in the register since
Declares membership of
- HCF - Helsinki Chemical Forum
- https://helsinkichemicalsforum.messukeskus.com/
- ENES - Exchange Network on Exposure Scenarios
- http://echa.europa.eu/en/about-us/exchange-network-on-exposure-scenarios
- HBM4EU - Human Biomonitoring for Europe
- https://www.hbm4eu.eu/
- PARC - Partnership for the Assessment of Risks from Chemicals
- https://www.eu-parc.eu/
- Critical Chemicals Alliance
- https://single-market-economy.ec.europa.eu/sectors/chemicals/critical-chemicals-alliance_en
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Downstream Users of Chemicals Co-ordination Group (DUCC)
- Head office
- Brussels, Belgium
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
The Downstream Users of Chemicals Co-ordination group (DUCC) filed 8 positions between 31 May 2021 and 2 Dec 2025, across 6 of the 665 legislative files tracked here, attaching a full position paper 6 times.
2021 · 3 filed2022 · 2 filed2023 · 1 filed2024 · 1 filed2025 · 1 filed
What they argued
DUCC urges the European Commission not to rush decision-making processes for CLP (or any other legislation) in order to meet unrealistic deadlines, set in the CSS, but to ensure that these are conducted properly in line with the principles of Better Regulation.
DUCC members are highly committed to successfully implement REACH which has been one of the most important regulations to ensure consumers and products safety in Europe on chemical risks. However, DUCC is of the opinion that any future actions to be taken should preferably involve using and strengthening existing tools as the set goals could be achieved by securing an overall better implementation of REACH…
The Downstream User of Chemicals Coordination Group (DUCC), representing 11 European associations whose member companies use chemicals to formulate mixtures, provides the following response to the OSOA public consultation.
The Downstream User of Chemicals Coordination Group (DUCC), representing 11 European associations whose member companies use chemicals to formulate mixtures raises the following with regards to the proposal of Commission to remove ‘improve access to chemicals data by removing technical and administrative obstacles’.
DUCC position on the proposal for a Regulation on the European Chemicals Agency 2 December 2025 The Downstream Users of Chemicals Co-ordination Group (DUCC) is a platform of 11 European associations which represent “downstream” industries ranging from cosmetics and detergents to aerosols, paints, inks, toners, pressroom chemicals, adhesives and sealants, construction chemicals, fragrances, disinfectants, lubricants…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Downstream Users of Chemicals Co-ordination group (DUCC) welcomes any initiative that aims at improving protection, while fostering investment that can be justified from an economic, social, and environmental perspective for a digital transition. DUCC members are keen to engage with stakeholders on priority information to leave on packaging and supplementary information to be made available online.
DUCC is a platform of 11 European associations which represent downstream formulating industries from: cosmetics, detergents, aerosols, paints, inks, toners, pressroom chemicals, adhesives and sealants, construction chemicals, fragrances, lubricants, crop protection and chemical distributors industries.
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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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Everything on this page comes from The Downstream Users of Chemicals Co-ordination group (DUCC)’s own submissions to the European Commission. We have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
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.