CHEM Trust

Protecting humans and wildlife from harmful chemicals

CHEM Trust EU policy submissions and letters

2026

Joint NGO follow-up comments on the 58th CARACAL meeting, July 2026

  • Along with HEAL, CHEM Trust submitted comments on reproductive toxicity.
  • Along with HEAL and Client Earth, CHEM Trust submitted comments on notifications for new hazard classes.

Comments on the CARACAL 58 presentation on the updated Restrictions Roadmap, July 2026

Comments on ECHA’s public consultation on the classification proposal for TXIB, June 2026

Comments on ECHA’s public consultation on the classification proposal for chloroethane, June 2026

Comments on public consultation on the proposed restriction of CMRs in childcare products, May 2026

  • CHEM Trust submitted comments in response to a public consultation by the European Commission on the proposed restriction of CMRs in childcare products.

Comments on ECHA’s public consultation on SEAC’s draft opinion on the proposed EU PFAS restriction, May 2026

Comments on ECHA’s public consultation on the classification of 1H-benzotriazole and its inorganic salts, May 2026

  • CHEM Trust submitted comments in response to ECHA’s public consultation on the proposed CLH classification of 1H-benzotriazole and its inorganic salts.

Comments on ECHA’s public consultation on the classification of Methyl-1H-benzotriazole and its inorganic salts, May 2026

  • CHEM Trust submitted comments in response to ECHA’s public consultation on the proposed CLH classifications of Methyl-1H-benzotriazole and its inorganic salts.

Joint NGO letter to REACH Committee on CMRs in childcare, lead in ammunition and fishing tackle, and the ‘Restrictions Roadblock’ report, April 2026

Comments on ECHA’s public consultation on the classification of melamine, April 2026

  • CHEM Trust submitted comments in response to ECHA’s public consultation on the proposal to classify melamine as persistent, mobile and toxic under the CLP regulation.

Comments on ECHA’s public consultation on the proposed restriction of octocrilene, March 2026

  • CHEM Trust submitted comments in response to ECHA’s public consultation on the proposal to restrict octocrilene in cosmetic products.

Comments on ECHA’s call for evidence on certain non-polymeric additive ABFRs, March 2026

  • CHEM Trust submitted comments in response to ECHA’s call for evidence on certain non-polymeric additive aromatic brominated flame retardants.

Comments on ECHA’s public consultation on the classification of medium-chain ortho-phthalates, March 2026

  • CHEM Trust submitted comments in response to ECHA’s public consultation on the proposal to classify medium-chain Ortho-phthalates as reprotoxic and endocrine disruptors for human health under the CLP regulation.

Joint NGO statement to EU leaders calling for stronger protections against harmful chemicals, February 2026

  • CHEM Trust and other NGOs made a statement to EU leadership asking that they deliver safe chemicals with high protection of people’s health and the environment.

Joint NGO comments as follow-up to 56th CARACAL meeting, February 2026

  • CHEM Trust and HEAL published comments on two agenda items from the 56th CARACAL meeting.

Comments on ECHA’s public consultation on the classification of tris[2-chloro-1-(chloromethyl)ethyl] phosphate (TDCP), February 2026

  • CHEM Trust comments in response to ECHA’s public consultation on the proposal to classify TDCP as reprotoxic and an endocrine disruptor for human health under the CLP regulation.

Comments on ECHA’s public consultation on the classification proposal for the reaction products of phosphorus oxychloride and propylene oxide (TCPP), February 2026

  • CHEM Trust comments in response to ECHA’s public consultation on the proposal to classify TCPP as carcinogenic and reprotoxic and an endocrine disruptor for human health under the CLP regulation.

Comments on ECHA’s public consultation on the classification of sodium fluoride, January 2026

  • CHEM Trust comments in response to ECHA’s public consultation on the proposal to classify sodium fluoride as reprotoxic and an endocrine disrupting chemical under the CLP regulation.

2025

Comments on ECHA’s public consultation on the classification of N’,N’-diethylpropane-1,3-diamine (DEAPA) and N’,N’-dimethylpropane-1,3-diamine (DMAPA), October 2025

  • CHEM Trust comments in response to ECHA’s public consultation on the proposal to classify N’,N’-diethylpropane-1,3-diamine (DEAPA) and N’,N’-dimethylpropane-1,3-diamine (DMAPA),  as reprotoxic and endocrine disrupting chemicals under the CLP regulation.

Joint NGO letter to the President of the EU Commission calling for stronger implementation of EU pesticides law, October 2025

  • Along with 137 other organisations, CHEM Trust signed a joint letter led by PAN Europe addressed to Ursula von der Leyen, the President of the Commission.
  • The letter called for better implementation of the pesticides regulation in the EU.

Comments on new SVHC identification proposals, October 2025

  • CHEM Trust comments on new SVHC identification proposals.

Comments on ECHA’s public consultation on the SVHC identification of DBDPE, August 2025

  • CHEM Trust comments in response to ECHA’s public consultation on the proposal to identify DBDPE, a widely used flame retardant, as a Substance of Very High Concern (SVHC).

Comments on ECHA’s public consultation on the classification of Propylparaben, August 2025

  • CHEM Trust comments in response to ECHA’s public consultation on the proposal to classify Propylparaben as an endocrine disrupting chemical under the CLP regulation.

Comments on public consultation for the evaluation of the Cosmetic Products Regulation, July 2025

CHEM Trust signed Break Free From Plastic’s ‘Manifesto for a Future Free From Plastic Pollution‘, July 2025

  • Ahead of the August negotiations on The Global Plastics Treaty, BFFP launched a Manifesto calling for a strong Treaty, including the elimination of chemicals and groups of chemicals across the lifecycle of plastics that are hazardous to human health, biodiversity, and the environment.

Comments on ECHA’s public consultation on the classification of TFA, sodium TFA and other inorganic salts of TFA, July 2025

  • CHEM Trust comments in response to ECHA’s public consultation on the proposal to classify TFA, sodium TFA, and other inorganic salts of TFA as toxic to reproduction category 1B and PMT/vPvM chemicals, amongst others, under the CLP regulation.

Joint CSO statement welcoming a declaration on the Global Plastics Treaty, June 2025

  • CHEM Trust signed onto a statement along with 236 other CSOs welcoming a declaration from over 90 countries during the UN Ocean Conference. The declaration reaffirmed the countries’ commitment to an ambitious global plastics treaty and includes a call for a legally binding obligation to phase out the most problematic chemicals of concern in plastic products.

Joint NGO comments on the proposed amendments to REACH Annex XI (general rules for adaptation of the testing regime), April 2025

CHEM Trust comments on a Commission presentation on options for REACH revision given at CARACAL on 3rd April 2025

Joint NGO comments as follow-up to CARACAL discussion on update of REACH information requirements for ecotoxicological information and toxicokinetics, March 2025

  • CHEM Trust, EEB and HEAL comments on the proposals for changing the REACH annexes, following CARACAL subgroup meeting on 24th March 2025.

Joint NGO letter to the Commission with the call for an ECHA mandate to restrict aromatic brominated flame retardants, March 2025

  • CHEM Trust, Arnika, Cancer Prevention, ChemSec, ClientEarth, EEB, Fidra, HEAL, Zero Waste Europe sent a letter to the Commission to prepare a restriction dossier for aromatic brominated flame retardants.

Joint NGO letter to Executive Vice-President Séjourné on the revision of the Toy Safety Directive, March 2025

  • CHEM Trust and 35 other NGOs sent a letter to Executive Vice-President Séjourné. Response received April 2025.

Response to the EU Commission’s call for evidence on the Strategic Foresight Report, March 2025

  • CHEM Trust’s response to the EU Commission’s call for evidence to inform the Strategic Foresight Report 2025.

Comments on ECHA’s public consultation on the classification of Resorcinol, March 2025

  • CHEM Trust comments in response to ECHA’s public consultation of the proposal to classify Resorcinol as endocrine-disrupting chemicals under the CLP regulation.

Joint NGO comments as follow-up to CARACAL discussion on update of REACH information requirements for endocrine disrupters, February 2025

  • CHEM Trust, EEB and HEAL comments on the proposals for changing the REACH annexes, following CARACAL subgroup meeting on 18th February 2025.

REACH revision 2025: simpler, faster, bolder, February 2025

Key questions on EU Chemicals Policy for this Commission: CHEM Trust response, January 2025

Joint civil society letter to European Commission President regarding PFAS, January 2025

  • CHEM Trust signed onto a joint civil society letter alongside 93 other organisations, calling for President von der Leyen to defend a comprehensive universal PFAS restriction.

2024

Joint NGO letter to the REACH Committee on delays in implementation, December 2024

  • CHEM Trust supported the joint NGO letter to Members of the REACH committee on the delays in the implementation of the Restrictions Roadmap. 

Joint NGO letter to the Environment Council of the EU on EDCs, December 2024

  • CHEM Trust, as a member of the EDC Free Europe coalition, supported the letter sent to Members of the Environment Council of the EU calling for a more effective protection of health and the environment from endocrine-disrupting chemicals.

Comments on the Commission’s call for evidence on the roadmap for phasing out animal testing, October 2024

  • CHEM Trust comments in response to the Commission`s call for evidence on the development of a roadmap to phase-out animal testing in chemical safety assessments.

Joint NGO comments on the proposal following the CARCAL meeting, CLP session, September 2024

  • CHEM Trust and EEB comments regarding the proposal for a subgroup on test methods as follow-up to CARACAL meeting July 2024.

Joint NGO letter to UNEP and WHO on updating the state of the science of endocrine disrupting chemicals, July 2024

  • CHEM Trust submitted a letter to UNEP and WHO on avoiding conflicts of interest in the process of updating the EDC state of the scientific report.

Joint NGO comments on ECHA`s second call for evidence on aromatic brominated flame retardants, June 2024

Joint letter to the Council of the European Union on the Toys Safety legislation, April 2024

  • CHEM Trust signed onto a joint NGO letter calling for the Council of the European Union to support the European Parliament’s vote to restrict the most harmful chemicals in children’s toys under the revised Toys Safety legislation.

Comments on ECHA’s call for evidence on aromatic brominated flame retardants, April 2024

Comments on the draft regulation on the use of BPA and other bisphenols in certain food contact materials, March 2024

  • CHEM Trust submitted comments on the Commission’s draft regulation on the use of BPA and other bisphenols and their derivatives with harmonised classification for specific hazardous properties in certain materials and articles intended to come into contact with food.

Joint letter to Members of the European Parliament on the Toys Safety legislation, March 2024

  • CHEM Trust signed onto a joint NGO letter calling for the revised Toys Safety legislation to restrict the most harmful chemicals in children’s toys.

Joint letter to Member States on the possible vote on the restriction of PFHxA

  • CHEM Trust signed onto a joint NGO letter to Member States on 23rd February on the discussion and possible vote on the restriction of PFHxA, its salts and PFHxA related substances.

 

Policy statements from previous years

Please see this page for archived EU and UK policy submissions.

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