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 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 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.
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.
2nd Workshop on Assessment of Alternative substances
Good decision making backed up with a robust Assessment of Alternative substances is key to avoiding unintended impacts on the European society triggered by the ban of a substance. EFCC wishes to engage with Member States, European Commission, ECHA, NGOs as well as experts to address the related complex questions and look for solutions. Join our second workshop coordinated by the Downstream Users of Chemicals Coordination Group (DUCC) focusing on how to set up a body supporting the Assessment of Alternatives. The event will be live streamed on LinkedIn on on 24 April from 13:30 CET.
Rules on the new hazard classes under CLP are in force as of today
The rules on the new hazard classes under are in force as of 20 April 2023. For new substances on the market, companies need to comply with the new rules from 1 May 2025, whereas substances that have already been on the EU market, companies have until 1 November 2026 to comply. Separate transition times apply for mixtures. New hazard classes apply from 1 May 2026 to new mixtures, whereas companies have until 1 May 2028 to update the classification and labelling for existing mixtures. ECHA has published a new page on their website regarding the new hazard classes under CLP.
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).