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CHEM Trust policy submissions and letters

2019

CHEM Trust’s comments on the European Commission’s ‘Roadmap’ for its “Fitness Check on Endocrine Disruptors”, July 2019

  • On 10th July 2019 CHEM Trust submitted our comments on the European Commission’s ‘Roadmap‘ outlining how it will carry out a ‘fitness check’ of the EU’s laws relating to endocrine disrupting chemicals.

CHEM Trust’s submission to the UK Government’s consultation on the updated Marine Strategy Part 1, June 2019.

  • On 20th June 2019, CHEM Trust responded to the UK Government’s consultation on the Marine Strategy Part 1: UK Updated Assessment and Good Environmental Status.

Joint NGO letter to European Commissioners regarding delay in publication of report on EU chemicals legislation, June 2019.

  • On 17th June 2019 CHEM Trust joined with a number of other NGOs to write to the European Commission to ask why their ‘Fitness check’ on EU chemicals legislation (excluding REACH) had not been published.

A joint letter from EU civil society organisations calling for EU leaders to commit to prioritise sustainable development, June 2019.

  • CHEM Trust signed up to a joint civil society letter to EU leaders prior to their June summit, calling for sustainable development to be the overarching objective of the European Union’s priorities, both inside and outside Europe, for at least the next five years.

CHEM Trust letter to the Secretary of State for the Environment, Food and Rural Affairs, Michael Gove, on the upcoming identification of HFPO-DA as a SVHC, June 2019.

  • Ahead of the Member State Committee meeting at the EU Chemicals Agency, CHEM Trust sent a letter to Secretary of State Michael Gove supporting the identification of the persistent and mobile chemical HFPO-DA (used in ‘GenX’) as a substance of very high concern under REACH. The response to our letter with the UK statement is available here.

Legal letter from Leigh Day on behalf of CHEM Trust to the UK Government about deficiencies in the Government’s proposals for UK pesticides and REACH laws in the event of a no-deal Brexit, June 2019.

CHEM Trust’s submission to the European Commission’s consultation on the evaluation of the rules for chemicals in food contact materials, May 2019.

CHEM Trust letter to the Secretary of State for the Environment, Food and Rural Affairs, Michael Gove, on action needed on POPs, April 2019.

  • Ahead of the ninth meeting of the Conference of the Parties to the Stockholm POPs Convention (COP-9) in Geneva, Switzerland on 29 April to 10 May 2019, CHEM Trust sent a letter to the Secretary of State for the Environment, Food and Rural Affairs, Michael Gove, asking for action to reduce global pollution from Persistent Organic Pollutants (POPs). We received a response from Dr Therese Coffey MP assuring that the UK Government was commited to eliminating POPs.

CHEM Trust letter to the Secretary of State for the Environment, Food and Rural Affairs, Michael Gove, on chemical regulation protections post-Brexit, April 2019.

  • CHEM Trust sent a letter to the Secretary of State for the Environment, Food and Rural Affairs, Michael Gove, outlining concerns about the Statutory Instrument (SI) on REACH.

CHEM Trust submission to UK Parliament Environment Audit Committee inquiry on Toxic Chemicals in Everyday Life, March 2019

Response to the Department for Environment, Food & Rural Affairs’ consultation on draft indicators in the 25 Year Environment Plan, January 2019.

  • CHEM Trust responded to DEFRA’s request for comments on the draft indicators to be used to show environment change and measure progress in the 25 Year Environment Plan.

2018

Response to the Royal College of Paediatrics and Child Health’s call for evidence regarding indoor air quality, December 2018.

  • CHEM Trust responded to the RCPCH’s call for evidence on the effects of indoor air quality on children and young people’s health.

Response from 22 Civil Society Organisations to the EU Recast Regulation on Persistent Organic Pollutants, November 2018.

  • CHEM Trust co-signed, with 21 other environmental and consumer organisations, a joint letter calling for amendments to the Regulation on Persistent Organic Pollutant (POPs) in line with the EU’s obligations under the Stockholm Convention.

Letter to EU Commissioners regarding the negotiations on the UK’s post-Brexit relationship with REACH, October 2018.

  • CHEM Trust and the European Environmental Bureau sent a letter to EU Comissioners regarding the negotiations on the UK’s post-Brexit relationship with the EU chemicals regulation REACH.

Manifesto for rigorous science, safe food and a healthy environment by the European coalition: Citizens for Science in Pesticide Regulation, October 2018.

  • CHEM Trust co-signed with more than 110 NGOs, scientific and legal experts across Europe a joint manifesto calling upon the Regulators to fully reform the current pesticide risk assessment and risk management systems to a higher level of protection for health and environment. The manifesto is the initiative of the new coalition “Citizens for Science in Pesticide Regulation”.

Response to the European Commission public consultation addressing the interface between chemical, product and waste legislation, October 2018.

Response to the European Chemical Agency’s consultation on their plans for a database of SVHCs in articles, October 2018.

  • A CHEM Trust response to an ECHA consultation on creating a database of articles containing SVHC chemicals, as part of implementation of the revised Waste Framework Directive.

Join call for action addressed to the UK Government and the Stockholm Convention regarding PCBs in the ocean, September 2018.

  • CHEM Trust has joined 13 UK charities in a call for action from the UK Government in the Environment Act and at the Stockholm Convention in May 2019 to help prevent further polychlorinated biphenyl (PCB) toxic chemical waste entering our oceans and killing our mammals. See our comments here.

Comments on the UK Government’s plans for chemical regulation in the event of a no deal Brexit, July/Sep 2018

Response to EFSA’s consultation on MIXTOX Guidance, September 2018

  • CHEM Trust submitted a response to EFSA’s public consultation on the MIXTOX Guidance, a draft Guidance on harmonised methodologies for human health, animal health and ecological risk assessment of combined exposure to multiple chemicals,  September 2018.

NGO’s feedback on ECHA’s “Note on substance identification and the potential scope of a restriction on uses of ‘microplastics’”, September 2018

Letter to global government representatives demanding stricter standards on the plastic waste trade, September 2018

  • CHEM Trust co-signed an open letter calling for more transparency and regulation in the plastic trade. The letter has been delivered to world government representatives ahead of the working group meeting on Basel Convention (3-6 September 2018).

Letter to EC president expressing concerns about the EU proposal for SCCPs waste limits under the Basel and Stockholm conventions, September 2018

Join statement on future actions on per- and polyfluoroalkyl substances (PFASs), August 2018.

Letter to rapporteurs of the EU single-use plastic legislation regarding sanitary products, August 2018

Submission to the European Commission’s consultation on Roadmap for a new EDC Framework, July 2018

Letters to Commissioners and Member State representatives on the REACH committee regarding the proposed restriction on four phthalates, July 2018

  • CHEM Trust sent a letter to EU Commissioners Bienkowska, Vella, Andriukaitis and Timmermans, and co-signed (with European Environment Bureau), a second letter to Member State experts on the REACH committee, both calling for the proposed REACH Restriction on four phthalates to be extended to cover use of these phthalates in Food Contact Materials. The REACH committee letter has been covered by Chemical Watch and Food Packaging Forum.
  • Unfortunately the Food Contact uses were not added to the REACH Restriction; see also DG Grow’s reply to our letter to Commissioner Bienkowska.

Joint statement on Marine Litter and Microplastics, May 2018

Response to the European Chemical Agency call for evidence on the use of intentionally added microplastic particles in products of any kind, May 2018

  • CHEM Trust’s response to the European Chemicals Agency’s call for evidence on the use of intentionally added microplastic particles in products of any kind.

Response to Ökopol’s survey on specific PFASs (C4-C7) and other fluorinated substances (precursors or similar substances) to develop a restriction proposal under REACH, April 2018

  • CHEM Trust’s response to Ökopol’s survey on specific PFASs (C4-C7) and other fluorinated substances (precursors or similar substances) to develop a restriction proposal under REACH.

Letters to EU authorities on grouping of chemicals, in particular bisphenols, March 2018

Response to European Commission consultation on pharmaceuticals in the environment, February 2018

Comments on the consultation on EU Guidance for the identification of Endocrine Disruptors, January 2018

  • CHEM Trust submitted our comments to the European Chemicals Agency’s consultation on the EU Guidance for the identification of Endocrine Disruptors.

Policy statements from previous years