CHEM Trust EU policy submissions and letters

2023

Joint letter to Commissioner Sefcovic, November 2023

CHEM Trust signed onto a joint NGO letter to Commissioner Sefcovic, calling for deliverance of the commitments made in the 2020 Chemical Strategy for Sustainability within this Commission’s mandate.

CHEM Trust response to the universal PFAS restriction proposal, September 2023

CHEM Trust submitted general comments, recommendations and additional supporting evidence in the context of the public consultation on the Annex XV restriction report on the restriction on the manufacture, placing on the market and use of PFASs.

Joint NGO comments as follow-up to CARACAL discussion on update of REACH information requirements (CASG-IR-ED/02/2023)

CHEM Trust, EEB and HEAL comments on the proposed amendment of REACH annexes, following CARACAL discussions in July 2023.

CHEM Trust input into an EU Commission initiative to prohibit production for export of chemicals banned in the EU, July 2023

CHEM Trust responded to the European Commission’s public consultation on prohibiting production for export of chemicals banned in the European Union

Joint statement on the uPFAS restriction, June 2023

CHEM Trust and HEAL joint statement presented at ECHA Committee for Risk Assessment discussion on the universal PFAS restriction RAC-65, 6 June 2023

Joint letter in support of microplastics restriction, April 2023

CHEM Trust signed onto a joint NGO letter to Members of the REACH Committee asking them to support the Draft Commission Regulation (EU) amending Annex XVII to the REACH Regulation (EC) No 1907/2006 as regards microplastics

Joint comments on REACH revision Information Requirements, April 2023

CHEM Trust, EEB and HEAL comments on REACH information requirements, following the CARACAL presentation on 28th March 2023.

CHEM Trust comments on the Flame Retardants Strategy, April 2023

CHEM Trust comments on the ECHA Flame Retardants Strategy, as presented to CARACAL 48 on 28th March 2023.

Response to CLP public consultation, March 2023

CHEM Trust response to the public consultation on the CLP revision proposal

Joint letter to Commissioner Breton, March 2023

CHEM Trust signed onto a joint letter to Commissioner Breton, calling for him to ensure the EU chemicals industry is on the right path to a toxic-free environment

Joint NGO letter to EU commission on REACH information requirements, February 2023

CHEM Trust signed a Joint NGO letter to the EU Commission on the need to update REACH information requirements to close data gaps

CHEM Trust comments to ECHA consultation on Bisphenols, January 2023

CHEM Trust comments on the restriction proposal for 4,4’-isopropylidenediphenol (Bisphenol A) and bisphenols of similar concern for the environment as part of the ECHA consultation

CHEM Trust response to an EU consultation on chemicals in food contact materials, January 2023

CHEM Trust responded to a consultation from the European Commission on the revision of EU rules on food contact materials, answering their questionnaire and submitting a short briefing with additional comments

2022

CHEM Trust comments on proposed nominations for Substances of Very High Concern, October 2022

CHEM Trust submitted comments on the proposed nominations for Substances of Very High Concern (SVHC)

CHEM Trust comments to public consultation on introduction of new hazard classes into the CLP regulation, October 2022

CHEM Trust submitted comments to the public consultation with regards to the European Commission’s draft Delegated Regulation introducing new hazard classes into the CLP regulation

Joint NGO letter to President Ursula Von der Leyen on REACH and CLP reforms, September 2022

CHEM Trust signed onto a letter to the President of the European Commission, Ursula von der Leyen, calling on EU decision makers to stay on track for regulatory reforms of CLP by October 2022 and REACH by March 2023

CHEM Trust comments to ECHA’s restriction proposal for PFAS in firefighting foams, September 2022

CHEM Trust submitted comments in the context of the consultation on the Annex XV restriction report on the restriction of Per- and polyfluoroalkyl substances (PFASs) in firefighting foams in September 2022.

Joint NGO letter to REACH committee regarding upcoming EU restriction on intentionally added microplastics, September 2022

CHEM Trust signed on to a NGO letter letter calling for changes to strengthen the upcoming EU restriction on intentionally added microplastics.

Joint NGO letter to ECHA on the PFHxA and PFAS in firefighting foams restriction, August 2022

The joint NGO letter is a follow up to our first letter sent in May 2022 and the subsequent response from ECHA received in June 2022. ECHA sent a response in September 2022.

CHEM Trust submission made to support EU Commission’s key initiatives on chemical safety, July 2022

CHEM Trust made a submission to support the Commission’s initiative on better access to chemicals data for safety assessments. Further information on the initiative here

Joint NGO letter sent on a bisphenols restriction, July 2022

CHEM Trust sent a letter together with other NGOs to the German Environment Ministry regarding the ban on the use of all bisphenols that pose a concern to the environment, with limited derogations.

Comments on the Background paper on the “Impact assessment of the extension of the generic approach to risk management under the REACH Regulation”, July 2022

As part of the European Commission’s impact assessment study of changes to REACH, they have commissioned consultants to examine costs and benefits of different options for extending the Generic Approach to Risk Management (GRA); We submitted comments on a draft report of this study.

CHEM Trust comments on an ECHA consultation on chemicals with endocrine disrupting properties, June 2022

CHEM Trust written comments on the ECHA consultation on endocrine disrupting properties for the environment of 4,4′- methylenediphenol (EC 210-658-2, CAS 620-92-8, “Bisphenol F”) and 4,4′-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol (EC 216-036-7, CAS 1478-61-1, “Bisphenol AF”) and its salts

CHEM Trust input into the revision of Cosmetic Products Regulation, June 2022

CHEM Trust contribution to the public consultation for the targeted revision of the Cosmetics Products Regulation

CHEM Trust and other NGOs object to EU chemical reforms potentially being put on hold

Joint NGO letter outlining concerns about delays to REACH revisions discussed at the Plenary debate on “The social and economic consequences for the EU of the Russian war in Ukraine” (4 May 2022)

CHEM Trust response to the consultation on the Toy Safety Directive, May 2022

CHEM Trust responded to the European Commission’s public consultation on Protecting children from unsafe toys and strengthening the Single Market – revision of the Toy Safety Directive.

Joint NGO letter to ECHA, DG Grow and DG Environment on the PFHxA and PFAS in fire fighting foam restrictions, May 2022

8 NGOs expressed their concerns regarding the delay with the PFHxA restriction and the weaker proposal of the restriction on PFAS in firefighting foams. Read the NGO letter and ECHA’s response.

CHEM Trust response to the targeted stakeholder survey on Essential Use, May 2022

Following up to the workshop organised by Wood on the study supporting the Commission in developing an essential use concept CHEM Trust has been contacted to respond to a survey. Read our response here.

CHEM Trust response to the consultation on the targeted revision of the REACH regulation, April 2022

This is part of the ongoing REACH revision taking place under the implementation of the Chemicals Strategy for Sustainability

CHEM Trust comments on implementing the Generic Risk Management Approach (GRA), April 2022

CHEM Trust comments on the European Commission’s CARACAL document CA/19/2022 on options to implement the extension of the generic approach to risk management in the REACH Regulation.

CHEM Trust written comments on Essential Use Concept, March 2022

Follow up to the workshop organised by Wood on the study supporting the Commission in developing an essential use concept – 3^rd March 2022. Read our comments here.

Joint NGO letter on Hazardous Chemicals and Food Safety – recycled plastic in food packaging (updated rules), March 2022

CHEM Trust and 26 other European civil society organisations sent an open letter to the EU Commissioner for Health and Food Safety, Stella Kyriakides, stating their concerns about the new draft Regulation concerning the placing on the market of plastic materials and articles with recycled/secondary plastic content intended for use in contact with food.

CHEM Trust input into the Commission survey on the Mixtures Assessment Factor, March 2022

This will build towards developing a proposal for introducing the Mixtures Assessment Factor concept in REACH. Read it here.

CHEM Trust comments on EFSA’s draft opinion proposing lowering the tolerable daily intake of bisphenol A, February 2022.

Read it here and find out more about EFSA’s reevaluation of the risks here.

Joint comments submitted by CHEM Trust, Client Earth, EEB & HEAL, as a follow-up to the 6th CASG-ED meeting regarding:

The introduction of hazard classes for endocrine disruption in the CLP Regulation;
The update of REACH Annexes in relation to endocrine disruption properties

Brief comments on European Commission papers, in follow up to a CARACAL meeting, February 2022

Our comments on the potential options to reform REACH authorisation and restriction processes focused on the potential role of grouping, as well as supporting a more detailed submission from EEB.
Joint NGO comments on the update of REACH information requirements

CHEM Trust comments as follow-up to the Commission workshop on the possible increased use of the concept of Derived Minimal Effect Level (DMEL) for non-threshold substances in REACH on 31 January 2022

Joint NGO letter to the European Commission asking them to support the French proposal for an EU restriction of highly hazardous substances in single-use baby diapers, January 2022

The letter asked the Commission to support the restriction based on the vulnerability of newborns and toddlers to hazardous chemicals

Policy statements from previous years

Since 2020 submissions to UK policy are listed on a separate page: