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.
EFCC signed a joint construction industry statement on delivering the EU's renovation agenda
On 27 October 2022 EFCC signed a joint construction industry statement inviting Members of the European Parliament to give Europe’s construction industry the long-term investment certainty to be able to deliver the EU's renovation agenda.
EFCC position on the European Commission initiative introducing new hazard classes under CLP Regulation
On 17 October 2022 EFCC submitted a reply to the EC consultation on the CLP Delegated Act for new hazard classes. EFCC members believe that any modification of the classification rules or any inclusion of a new hazard class in the CLP should be discussed and agreed by the UN GHS SCE first.
DUCC position paper on the impact of polymer registration on downstream user formulators
EFCC, as member of DUCC, contributed to the development of the DUCC position paper on the impact of polymer registration on downstream user formulators. In this paper DUCC members highlight the importance of polymers for downstream user formulators and point out key impacts related to the different proposals of the EC.
EFCC’s Feedback on the revision of the Energy Performance of Buildings Directive 2010/31/E (EPBD)