Response to the European Commission’s Road Map for its work on the circular economy, January 2020
- CHEM Trust and ChemSec called for the Commission’s Circular Economy action plan to contribute to a toxic-free environment in their joint response to the European Commission’s consultation on their road map for a “New Circular Economy Action Plan“.
A letter to the new EU Commissioner for Health and Food Safety, Stella Kyriakides, December 2019
- See this blog for details.
Joint NGO comments to the draft European regulation on PFOA, December 2019
- CHEM Trust joined with other NGOs to send comments to the public consultation on the draft regulation of the European Parliament and of the Council as regards the listing of perfluorooctanoic acid (PFOA), its salts and PFOA- related compounds.
CHEM Trust’s comments to European Food Safety Authority’s consultation on cumulative risk assessment of pesticides, November 2019.
- CHEM Trust submitted comments to EFSA’s public consultation on two assessments considering the effects of exposure to pesticide mixtures.
A joint letter to the incoming European Commission President, Ursula von der Leyen, November 2019.
- CHEM Trust joined with other NGOs to send a letter to the incoming president of the European Commission on the need for a new European Chemicals Strategy in order to deliver the European Green New Deal. The letter was accompanied by a more detailed Technical Annex. EEB published a press release highlighting the link to the EU’s Human Biomonitoring Programme.
CHEM Trust comments to EHCA’s consultations for the identification of two short-chain PFAS as SVHC, April 2019 and October 2019.
- CHEM Trust submitted comments to the European Chemical Agency consultation about the identification about two short-chain PFAS as substance of very high concern. HFPO-DA and its salts and its acyl halides in April 2019 and PFBS and its salts in October 2019. Our full comments and a description of the context can be found here.
A joint letter on a proposal for a restriction on tattoo inks and permanent make up, October 2019.
- CHEM Trust signed up to a joint NGO letter to the REACH committee for a restriction on tattoo inks and permanent make up.
A position paper on the registration of polymers, October 2019.
- CHEM Trust co-wrote a position paper with other NGOs, including the European Environmental Bureau and ChemSec, on the registration of polymers under REACH. This position paper has been signed by 22 NGOs.
Additional evidence for the evaluation of EU laws on chemicals in food contact materials, September 2019.
- CHEM Trust submitted a letter to the Commission’s consultants Ecorys providing additional evidence for their review of the EU’s laws on chemicals in food contact materials.
CHEM Trust’s comments on the proposed update of REACH Annexes related to data requirements for endocrine disruptors, August 2019.
- On 29th August CHEM Trust submitted comments to the CARACAL expert group on the proposed update of the REACH Annexes to include data requirements for endocrine disruptors.
A joint submission on PFHxS restriction, August 2019.
- CHEM Trust, EEB and IPEN sent joint comments to the European Chemical Agency public consultation on PFHxS restriction in August 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.
- On May 6th 2019, CHEM Trust responded to the Commission’s on-line consultation as part of their evaluation of the EU laws on chemicals in food contact materials, and also submitted a position paper as an additional contribution. We have also led the development of five key principles for future EU regulation of chemicals in food contact material.
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
- CHEM Trust submitted evidence to the UK Parliament’s Environmental Audit Committee inquiry into “Toxic Chemicals in Everyday Life“. You can see all the evidence for this inquiry on their evidence page.
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.
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.
- CHEM Trust responded to the EC consultation addressing the interface between chemical, product and waste legislation following the Commission’s Communication on the implementation of the circular economy package: options to address the interface between chemical, product and waste legislation.
- We also co-signed, with other NGOs, a position paper sent to the European Commission.
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
- Initial CHEM Trust comments on UK government plans for a new UK chemicals regulatory system in event of a no-deal Brexit, sent to the Government on 3rd July 2018, published on 25th September 2018 – see this blog for more details and and explanation for the delayed publication.
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
- CHEM Trust and three other NGO sent a letter to ECHA’s Microplastics Restriction Team to react on the aspects developed in the “Note on substance identification and the potential scope of a restriction on uses of ‘microplastics’” published in on 11th July 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
- CHEM Trust co-signed a letter addressed to the European Commission President Jean-Claude Juncker: “NGO Response to the EU Proposal for Short-chain Chlorinated Paraffins (SCCPs) Waste Limits under the Basel and Stockholm Conventions”. At issue is the recklessly high “low-POPs-content level” for SCCPs of 10,000 ppm that defines the level at which waste must be treated according to stringent Stockholm Convention obligations to destroy their POP content. The signatories ask for a limit at 100 ppm.
Join statement on future actions on per- and polyfluoroalkyl substances (PFASs), August 2018.
- CHEM Trust is a signatory party of the “Zürich Statement on Future Actions on Per- and Polyfluoroalkyl Substances (PFASs)” outlining a set of needs, goals, and actions to cooperatively work toward a more efficient and effective assessment and management of PFASs.
Letter to rapporteurs of the EU single-use plastic legislation regarding sanitary products, August 2018
- CHEM Trust co-signed with other NGOs a letter addressed to the rapporteur and shadow rapporteurs of the “Proposal for a Directive on the reduction of the impact of certain plastic products on the environment” at the EU Parliament to have four articles improved to make reusable and toxic-free sanitary products a reality.
Submission to the European Commission’s consultation on Roadmap for a new EDC Framework, July 2018
- CHEM Trust submitted our response to a European Commission consultation on a draft‘Roadmap “Towards a more comprehensive EU framework on endocrine disrupters”.
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
- CHEM Trust co-signed a joint statement endorsed by 83 organisations and submitted at the 1st meeting of the ad-hoc open-ended expert group on Marine Litter and Microplastics in Nairobi, 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
- CHEM Trust wrote to ECHA, the European Food Safety Authority (EFSA), and the European Commission’s Health Commissioner to ask them to restrict the use of groups of similar chemicals to prevent the substitution of one hazardous chemical with related chemicals that have similar properties. See the letters in our blog about our report “From BPA to BPZ: a toxic soup? How companies switch from a known hazardous chemical to one with similar properties, and how regulators could stop them”.
Response to European Commission consultation on pharmaceuticals in the environment, February 2018
- Read the blog on our response to the European Commission’s “Public consultation on pharmaceuticals in the environment“.
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.