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.