DUCC submits feedback to a European Commission’s public consultation
As a result of the European Commission call for evidence
consultation assessment on the explosives precursors Regulation, DUCC submitted the attached reply yesterday.
#hazardousproducts
Our media partner, Smithers, has shared with us an article that provides insight into the world of hot melt adhesives, sourced from the Smithers report The Future of Hot Melt Adhesives to 2027.
DUCC supports joint recommendation for clarity on Assessment of Regulatory Needs (ARNs)
ARNs, initiated by the European Chemical Agency (ECHA), serve as a preliminary step to evaluate the necessity of regulatory risk management for substances. After group assessments, 60% of substances are deemed not to require additional regulatory measures, while the remaining 40% necessitate further data collection to determine and implement appropriate regulatory risk management measures.
The ARN tool facilitates anticipation of potential regulatory actions, encouraging industry engagement in the process and proactivity in updating dossier information.
FEICA publishes paper on adhesives in the regulation of end-of-life vehicles
In July 2023, the EC published a proposal for a regulation on circularity requirements for vehicle design and end-of-life vehicles (‘ELV regulation proposal’, document COM(2023)451).
In this paper, FEICA argues that:
• The explicit and generalised mention of adhesives as an impediment to the dismantling and recycling in the ELV regulation proposal is inaccurate, as adhesives can allow for and even enable successful dismantling and recycling.
• The current wording constitutes an uneven playing field as other materials and bonding technologies which may prevent dismantling and/or recycling are not mentioned.
• The mention of specific materials or technologies which are to be considered in the circular design strategies and in fee modulation for vehicles should be provided, if at all, in secondary legislation or guidance only.
• Any mention of specific materials or bonding technologies should be sufficiently specific and reflective of the existing practices, successes and limitations of end-of-life vehicle dismantling and recycling.
Publication ref.:POP-EX-M12-059
#circulareconomy #sustainabledevelopment #ELV
Industry shares with the European Commission its reservations regarding the intention to nominate D4, D5 and D6 as persistent organic pollutants (POPs) under the Stockholm Convention
The nomination of D4, D5 and D6 as POPs put at risk their intermediate use to produce silicone polymers, as well as many applications of silicone polymers. Please also see
Annex A and
Annex B (POP nomination of D4, D5, D6).
Publication ref.: COS-EX-M11-058
Call for urgent dialogue and a rethink regarding CLP Revision – 3 key aspects that will have a major negative impact on industry and the environment
11 European associations (including FEICA) representing producers, product formulators (downstream users), distributors and end users of chemicals, expressed their strong concerns regarding the ongoing revision of the Regulation on Classification, Labelling and Packaging of substances and mixtures (CLP). While we acknowledge the importance of ensuring clear and concise information on product labels, we firmly believe that the impact of the changes proposed in the revised CLP regulation has been greatly underestimated in the European Commission's impact assessment, especially with regard to minimum requirements for labelling.
More info via the FEICA Extranet here.
Please share this LinkedIn post.
Publication ref.:COS-EX-M09-048
#CLP #classification&labelling
ASMoR Position Paper on Green Claims Directive
To ensure consumers can make sustainable consumption choices and contribute to a circular economy it is key that they are provided with reliable, comparable, and verifiable environmental information about goods or services they want to purchase. In this context, ASMoR, of which FEICA is a member, welcomes the goals and principles of the European Commission’s proposal for a Green Claims Directive (Directive on the substantiation and communication of explicit environmental claims) and the possibility of using internationally recognized methodologies to calculate and communicate the environmental impact of a product.
ASMoR’s paper on the proposal for a Directive on Green Claims has been published and can be consulted here.
The Alliance for Sustainable Management of Chemical Risk (‘ASMoR’) is an alliance of more than 30 members that share a common position on the Essential Use Concept (‘EUC’) in EU chemicals policy.
Publication ref.: COS-EX-M06-043
#REACH #hazardousproducts #sustainabledevelopment
FEICA provides input and co-signs ASMoR comments on the WSP essential use report - Policy options for REACH authorisation and restriction processes
This is ASMoR’s latest paper which responds to WSP’s report on Supporting the Commission in developing an essential use concept, commissioned by DG Environment. See here.
ASMoR, of which FEICA is a member, acknowledges the importance of the analysis of different policy options for REACH in the WSP report and supports the objective to make restrictions and authorisations more efficient and more predictable, to enhance the level of protection of human health and the environment when the use of a substance presents an unreasonable risk. However, the alliance is convinced that the current proposed approach and broad application of the essential use concept (EUC) will ultimately result in an equally burdensome process for managing chemicals and fail to address existing challenges. As a way forward, ASMoR recommends a more targeted application of the EUC in combination with derogations for safe uses as workable reformed risk management process.
The Alliance for Sustainable Management of Chemical Risk (‘ASMoR’) is an alliance of more than 30 members that share a common position on the Essential Use Concept (‘EUC’) in EU chemicals policy.
Publication ref.: COS-EX-M06-040
#REACH #hazardousproducts #sustainabledevelopment