EFCC position on the data handling aspects of the revised Construction Products Regulation (CPR))
EFCC supports the key objectives of the Construction Products Regulation (CPR) revision, and in particular the ones aimed at addressing the shortcomings of the current rules, enhancing the sustainability of construction products and contributing to the objectives of the green and digital transition of the European economy. However, EFCC members have been concerned about the planned introduction of a significant number of additional data sharing requirements. Members consider many of the additional data sharing requirements as not improving the accessibility of relevant digital product information for citizens and authorities, whilst adding a very significant administrative burden on the construction chemicals industry.
EFCC with other DUCC members released the last statement before the Council vote on the revision of the CLP
Tomorrow the European Council votes on the compromise proposal on the revised EU legislation on hazard classification, labelling and packaging of chemicals (CLP). EFCC with other downstream user associations reiterated their concerns related to the revised proposal. We request more flexibility on the labelling requirements and reasonable transition periods for the application of the new criteria. You can read more details below.
Cross industry request for a phased implementation of the Mixture Allocation Factor (MAF)
EFCC members have expressed many times their concern about the planned introduction of the Mixture Allocation Factor (MAF). Now, in June 2023, we reiterate this concern together with all DUCC member associations and SMEunited. We voice again that even a proposed MAF of 5 will have substantial impacts on the entire chemicals value chain, with serious knock-on effects on EU competitiveness and sustainability-driven innovations and only with very limited contribution to the safer use of chemicals and in most cases no benefits to end-users and society. If the MAF is introduced regardless of the concerns, we ask for its phased, stepwise, implementation and starting with substances with the greatest potential to contribute to unintentional co-exposure.
EFCC supports the joint statement on the draft Taxonomy Environmental Delegated Act
EFCC, as member of the Construction 2050 Alliance, supports the joint statement of its members on the draft Taxonomy Environmental Delegated Act published in April 2023. For the construction sector the recommendations of the draft Environmental Delegated Act show fundamental weaknesses in terms of the usability and practicability . Read more details below:
EFCC reaction to the EC (WSP) report (April 2023) on the Essential Use Concept
EFCC together with other ASMoR members presents its first reaction to the WSP report supporting the European Commission in developing an Essential Use Concept published in April 2023. The study and more specifically Appendix C do not fully reflect established facts nor contributions made by ASMoR and its members during the consultation. We would like to highlight the following: uses of most hazardous chemicals can be safe and, by discarding the possibility of ‘safe uses’ from the impact assessment, WSP is not giving the full picture of the consequences we object to extending the scope of the Essential Use Concept to industrial uses; contrary to what WSP states in the study, the EU’s chemicals strategy for sustainability (CSS) proposed it application to consumer uses and to a certain extent to professional uses ‘safe use’ has not been defined so far and we are willing to contribute to defining it.
EFCC position on the revision of hazard classification, labelling and packaging of chemicals (CLP)
Today EFCC submitted its position in reply to the public consultation on the European Commission proposal for the revision of EU legislation on hazard classification, labelling and packaging of chemicals (CLP).
EFCC's joint position with DUCC on the revised CLP
EFCC together with other Downstream Users of Chemicals Coordination Group (DUCC) members formulated its concerns about the new requirements of the revised Regulation on classification, labelling and packaging of chemicals (CLP).
The negative impacts of the blanket Mixture Assessment Factor (MAF)
The introduction of a blanket Mixture Assessment Factor (MAF) would have substantial negative impacts on EFCC members with questionable benefits. EFCC, together with DUCC members, prefers that the MAF applies only to substances that contribute to the mixture toxicity.