EFCC joined the signatories to the Antwerp Declaration
EFCC has joined the signatories to the Antwerp Declaration for a European Industrial Deal, launched in February 2024. The Antwerp Declaration calls for a ‘comprehensive action plan to elevate competitiveness as strategic priority and create the conditions for a stronger business case in Europe’. It is requested to be the first big policy initiative of the new European Commission which would complement and reinforce the European Green Deal and create clarity, predictability, and establish a targeted industrial policy.
Position on the proposal for a Regulation on a common data platform on chemicals
EFCC together with DUCC members expressed its support for the main objective of the OSOA approach presented under the Chemicals Strategy for Sustainability (CSS) to improve the efficiency, effectiveness, coherence, and transparency of issuing safety assessments of chemicals across different pieces of EU legislation. EFCC also welcomes the legislative proposal regarding the establishment of a Common Data Platform on Chemicals (CDPC) and takes the opportunity to express its concerns regarding the scope and definitions, study notifications, as well as confidentiality and data management in response to the EC public consultation.
Reiteration of the major negative impact on industry of the current CLP proposal regards minimum requirements for labelling
As a follow-up of the industry cross sector group letter of 5 September 2023, today industry released a new joint letter to reiterate the major negative impact on industry of the current CLP proposal as regards minimum requirements for labelling. In the new letter industry invites legislators to keep an open mind going in the trilogue discussions regarding minimum font size requirements.
EFCC position on the European positive list under the Drinking Water Directive
Today EFCC submitted its position in reply to the public consultation on the delegated act that supplements the Drinking Water Directive and that lays down the procedure for amending the European positive list of starting substances, compositions or constituents to be used in the manufacture of materials or products intended to be in contact with drinking water. EFCC is concerned that the increased data collection and analytical requirements planned to be required for the positive listing will put a significant burden of the manufactures and downstream users. In addition to this, EFCC considers that neither the DWD nor this implementing act provide sufficient protection for the shared data and confidential business information and as such is not protecting the intellectual property of the European economic operators. As downstream user formulators we fear that the number of applicants for the positive listing will be very limited resulting in a lack of substances available for drinking water materials after 2025. This would lead to a significant reduction of construction products available for drinking water installations which could put the distribution of the drinking water to European consumers via the pipe systems at risk.
EFCC joins cross-sector call for a rethink regarding CLP revision
EFCC together with several industry federations calls for urgent dialogue and a rethink regarding CLP Revision. We focus on three key aspects that will have a major negative impact on industry and the environment: - he new 6-month timeline for label updates instead of the 18 months transition period provided in Adaptation to Technical Progress (ATP) to CLP for harmonised classifications to become mandatory - the tabled amendment within the European Parliament to prohibit environmental claims on mixtures classified as hazardous or carrying supplemental labelling - the proposed requirement of a minimum font size - we suggest to follow ECHA’s guidance of 1.2mm x-height as the minimum font size
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.