OpenLobby.EU
Explore

Improving access to and availability, sharing and re-use of chemical data for the purpose of chemical safety assessments

Environment

This initiative will improve chemicals data access by removing technical and administrative obstacles, according to the principle that data should be easily findable, interoperable, secure, shared and re-usable. The initiative will strengthen the use of all available data and increase transparency. Furthermore, it will enable EU and national authorities, where necessary, to commission testing and monitoring of chemical substances as part of the regulatory framework.

Links

Public consultation

ID: 13459

Lobbying Activity

71 responses

Environmental groups demand stronger chemical risk early warning system

European Environmental Bureau, 3 Apr 2024

The organization wants mandatory regulatory action when emerging chemical risks are identified, not just warnings. They request authorities must respond to risks, outlining intended actions or justifying inaction. They also want industry to pay for testing under the polluters pay principle.
This would enable faster regulatory intervention to prevent chemical pollution incidents like PFAS contamination.
Chemical industry bears testing costs and faces faster restrictions on substances flagged as risky.

Titanium Dioxide Industry Seeks Nuanced Substance Classification in EU Data Platform

European Chemical Industry Council, 26 Mar 2024

The organization requests clear differentiation between different forms of titanium dioxide, particularly distinguishing food additive forms from pigment forms. They emphasize the need to preserve risk-based assessments that consider variations in substance use and exposure. They also advocate for maintaining independent scientific reviews and robust data quality standards.
This would prevent their main pigment products from being subjected to restrictions intended for other forms.
Public health advocates lose from narrow substance definitions that could limit safety assessments.

Chemical Industry Urges Limited Authority Powers on Data Access

European Chemical Industry Council, 16 Aug 2022

The industry supports data re-use between authorities but wants strict limits on new requirements. They request that dissemination focus on study summaries rather than full reports, and that any authority power to commission tests be limited to exceptional cases with EU budget funding. They warn against extending EFSA's transparency model to chemicals legislation.
This would protect commercially valuable information and avoid increased administrative burden from new transparency requirements.
Public interest groups lose broader access to full safety data on chemical substances.

EFPIA Demands Data Protection for Medicines in Chemicals Platform

European Federation of Pharmaceutical Industries and Associations, 3 Apr 2024

EFPIA demands that the European Medicines Agency leads medicinal risk evaluations. They request strict confidentiality for business studies and a full impact assessment.
These protections prevent the disclosure of sensitive drug research to global competitors.
Public research institutions face higher burdens to provide raw data and experimental protocols.

EFPIA calls for impact assessment on chemical data sharing

European Federation of Pharmaceutical Industries and Associations, 10 Aug 2022

EFPIA requests an impact assessment to prevent negative effects on medicine availability. They demand that data sharing rules respect regulatory data protection and keep company details confidential. They also call for alignment with pharmaceutical legislation revisions.
Maintaining data protection would safeguard their research investments and ensure market exclusivity.
Researchers and private groups lose access to raw data due to confidentiality restrictions.

ClientEarth demands industry pays for new chemical safety platform

ClientEarth AISBL, 29 Mar 2024

They urge for civil society representation in governance and the inclusion of enforcement data. They also insist that industry funding must cover all commissioned scientific studies.
This would provide environmental lawyers with better tools to monitor chemical risks.
Chemical companies would bear the financial burden of funding independent safety research.

Eurogroup for Animals urges data sharing to end animal testing

Eurogroup for Animals, 4 Apr 2024

They want mandatory data sharing to prevent redundant animal experiments. They also propose notifying authorities about planned studies before they begin. Finally, they suggest prohibiting results from studies not previously notified to regulators.
These measures would reduce the total number of animals used in safety assessments.
Chemical companies would face stricter rules and mandatory sharing of proprietary data.

Fuel Industry Seeks Lighter Data Rules for Chemicals Platform

FuelsEurope, 3 Apr 2024

FuelsEurope requests limiting notification requirements to hazard-relevant studies only, excluding straightforward physico-chemical property tests. They want notifications required only when studies conclude, not during research phases. The duty to notify should apply only to business operators, not contract research organizations.
This would reduce their administrative burden and compliance costs for chemical testing.
Regulators lose earlier visibility into planned chemical safety studies and testing programs.

Fuel Industry Seeks Protection for Commercially Sensitive Chemical Data

FuelsEurope, 16 Aug 2022

FuelsEurope requests protection for commercially sensitive information and intellectual property rights in data sharing systems. They want industry consultation before authorities commission tests, especially for complex petroleum substances. They also seek inclusion in the Expert Working Group implementing the policy.
This would preserve their competitive position and protect research and development secrets.
Public health advocates lose fuller transparency on chemical safety test data.

Medicines for Europe warns against ECHA control over pharmaceutical data

MEDICINES FOR EUROPE, 14 Mar 2024

The organization requests that pharmaceutical safety assessments remain under EMA control, not ECHA. They seek harmonization with ongoing pharmaceutical legislation revisions and clarification on avoiding duplicate submissions. They emphasize protecting proprietary data confidentiality.
This would prevent duplicate regulatory assessments and protect their proprietary pharmaceutical data.
Broader chemical safety oversight loses access to pharmaceutical environmental and toxicity data.

FoodDrinkEurope Urges Chemical Data Sharing With Strict IP Safeguards

FoodDrinkEurope, 16 Aug 2022

FoodDrinkEurope requests standardized protocols for data access to ensure consistency and predictability. They insist that data sharing must respect confidentiality and intellectual property rights. Furthermore, EFSA should remain the lead agency for food-related chemical risk assessments.
The industry would benefit from more efficient safety assessments for innovative sustainable packaging materials.
Companies investing in R&D could lose their competitive edge if intellectual property is disclosed.

Eurometaux demands strict quality standards for chemical data platform

EUROMETAUX, 3 Apr 2024

The group calls for transparent standards to verify data quality. They also request clear substance identification guidelines for different metal forms. Finally, they urge a nuanced approach to prevent oversimplifying complex scientific evidence.
This allows the industry to verify regulatory data against their own specialized metallic databases.
Policymakers and users risk taking incorrect actions based on oversimplified early warning indicators.

Eurometaux backs chemical data sharing while protecting business secrets

EUROMETAUX, 16 Aug 2022

Eurometaux supports consistent data reuse under the 'One Substance One Assessment' principle. They call for simple notification mechanisms that avoid unnecessary delays and protect confidential business information. Industry stresses that data owners' rights must be respected when implementing open data policies.
Streamlined data sharing would lower administrative costs and prevent redundant testing for metal producers.
Regulators and the public may face limited transparency to protect industrial property rights.

MedTech Europe urges ECHA funding and expertise safeguards in chemicals reform

MedTech Europe, 4 Mar 2024

The organization requests clarifications to optimize the legislative proposals, including ensuring ECHA has necessary expertise in medical devices, carrying out a formal Impact Assessment for additional resources, and providing adequate funding. They emphasize the need to streamline existing databases and clarify the interface between REACH and RoHS.
This would prevent delays and maintain legal certainty in the medical device exemption process.

CropLife Europe calls for harmonized chemical safety data standards

CropLife Europe, 28 Mar 2024

The association advocates for resolving diverging scientific opinions and ensuring academic data meets reliability standards. They also call for a pragmatic study notification system that safeguards intellectual property.
Harmonized assessments reduce market fragmentation and prevent competitors from accessing sensitive research.
Academic researchers may face increased scrutiny and administrative requirements for their published studies.

CropLife Europe urges clear rules for chemical data access

CropLife Europe, 16 Aug 2022

CropLife Europe requests a distinction between using property data and requiring full ownership for market access. They demand that transparency rules protect confidential business information and avoid overinterpreting harvested data.
This would reduce the costs and administrative burdens of obtaining full study reports for market access.
Companies owning the original research risk losing competitive advantages through potential commercial misuse.

L'Oréal seeks tighter definitions for chemical data sharing

L'Oréal, 3 Apr 2024

L'Oréal requests narrowing the scope of studies subject to mandatory notification. They also advocate for protecting proprietary information via the originator principle.
The company would avoid significant administrative costs and protect sensitive research.
Transparency advocates lose access to chemical safety datasets restricted by confidentiality.

German Chemical Industry Urges Changes to EU Data Platform Proposal

Verband der Chemischen Industrie e.V., 12 Feb 2024

The organization requests industry consultation before implementation decisions, cross-checks with industry expertise on data generation mechanisms, and significant modifications to study notification requirements. They argue the notification obligations lack clarity and proportionality.
This would reduce administrative burdens and preserve competitive advantages over non-EU companies.
Regulators and public health advocates lose transparency into industry testing activities and chemical safety data.

Cosmetics Europe demands safety committee autonomy in chemicals overhaul

Cosmetics Europe, 2 Apr 2024

The industry insists the Scientific Committee on Consumer Safety remains a stand-alone body. They also demand that risk assessment remains the primary basis for safety decisions.
This preserves specialized industry standards and prevents broader bans based only on hazard.
Consumers lose out as safety evaluations become less precautionary and more complex.

Merck warns chemical data proposal creates excessive administrative burden

Merck, 21 Mar 2024

Merck requests a precise definition of which studies require notification to authorities. They suggest limiting the scope to studies that have clear regulatory relevance. They also emphasize protecting confidential business information from accidental disclosure.
Limiting the scope would reduce the significant administrative costs and resource requirements.
Authorities might make incorrect safety assessments if they lack specific chemical context.

Detergent industry urges data re-use while protecting business secrets

Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien, 16 Aug 2022

They support re-using data to avoid new testing while ensuring assessments remain tailored. Data sharing must protect business secrets and research to safeguard innovation.
This would lower costs and reduce administrative burdens for detergent manufacturers.
Innovative companies would lose competitive advantages if research data is disclosed.

Self-care industry urges confidentiality protections in chemical data sharing

Association of the European Self-Care Industry, 3 Apr 2024

The organization demands a full impact assessment and stronger confidentiality safeguards for sensitive data. They insist the European Medicines Agency must retain primary authority over health product evaluations.
These measures would protect proprietary manufacturing secrets and prevent non-specialist agencies from restricting medicines.
Environmental monitoring groups and the public would face delays in identifying emerging chemical risks.

Self-care industry urges transparency for new chemical data rules

Association of the European Self-Care Industry, 16 Aug 2022

AESGP requests a formal impact assessment and clear written guidelines for this initiative. They advocate for a reporting mechanism to ensure the rules simplify existing processes. They also seek to review cost-benefit analyses before policies are finalized.
This would prevent unexpected compliance costs and ensure new rules actually simplify reporting.

Humane World for Animals urges EU to drop testing mechanism

Humane World for Animals Europe, 16 Aug 2022

The group wants the new data-generation mechanism eliminated to prevent redundant studies. They argue that if retained, a full impact assessment is mandatory.
The group would prevent unnecessary animal suffering by blocking a broad new testing mandate.
Animals and welfare advocates suffer if the proposal enables virtually limitless new animal testing.

CHEM Trust urges transparency in EU chemical safety assessments

Chemicals, Health and Environment Monitoring Trust, 29 Jul 2022

CHEM Trust seeks to transfer transparency principles from food safety to all chemical laws. They support increasing transparency to avoid animal testing and strengthening authority powers to commission monitoring.
This policy would improve the speed and effectiveness of measures protecting health and nature.
Industry players providing insufficient data would lose control as authorities commission their own testing.

AnimalhealthEurope urges removing GMOs from chemical data platform

AnimalhealthEurope, 4 Apr 2024

The group requests removing genetically modified organisms and medicated feed from the scope. They argue the regulation should only share existing data without creating new reporting burdens. Finally, they insist on protecting confidentiality rules currently managed by the medicines agency.
This would lower compliance costs and prevent confusion between chemical and biological rules.
Regulatory agencies face heavy workloads that could compromise their ability to perform core duties.

AnimalhealthEurope urges protection of commercial secrets in data sharing

AnimalhealthEurope, 16 Aug 2022

The organization argues that data sharing should be limited to public authorities to prevent competitors from benefiting for free. They request that the Commission protect intellectual property and ensure data owners are compensated if third parties use their files.
These protections would preserve the market value of their research and prevent rival firms from copying products.
Smaller commercial competitors lose the chance to use existing safety data to lower their entry costs.

Textile industry demands data security and SME notification exemptions

EUROPEAN APPAREL AND TEXTILE CONFEDERATION, 4 Apr 2024

EURATEX calls for the protection of sensitive business information to maintain industry competitiveness. They suggest exempting innovation-related studies from notification requirements to lower administrative burdens for small enterprises. Finally, they advocate for a stronger enforcement role for the European Chemicals Agency.
Exemptions and confidentiality would safeguard proprietary innovations and decrease operational costs for SMEs.
Regulatory bodies and the public lose transparency if innovation-related chemical data remains undisclosed.

German Social Insurance Urges Wider Access to Chemical Data

Deutsche Sozialversicherung Europavertretung, 20 Mar 2024

DSV requests that social insurance agencies and scientific bodies receive full access to the database. They also recommend that technical agency experts lead the governance structure.
This would allow insurers to better monitor workplace hazards and standardize safety across the EU.
The European Commission loses executive control if its unilateral lawmaking power is strictly limited.

ChemSec Urges Civil Society Inclusion in Chemical Data Platform Governance

International Chemical Secretariat, 4 Apr 2024

ChemSec calls for chemical data to be readily available to all relevant actors. They recommend including civil society organisations in the steering and governance of the platform. The group also welcomes the proposal to introduce an independent data generation mechanism.
Wider access to data helps the group investigate obscure parts of the chemical market.
Certain companies lose the benefit of keeping chemical safety data hidden from public view.

ChemSec urges stricter confidentiality rules for chemical data transparency

International Chemical Secretariat, 16 Aug 2022

ChemSec calls for a review of confidentiality policies to make claims harder to justify. They suggest centralizing data handling at ECHA to improve access for authorities and NGOs. This would ensure assessments use the same data for consistent outcomes.
Increased transparency would accelerate efforts to replace the most hazardous substances in products.
Organizations that use confidentiality claims to hide data will find it harder to operate.

SSNC urges full transparency in EU chemical data platform

Swedish Society for Nature Conservation, 4 Apr 2024

SSNC requests including peer-reviewed scientific data and chemicals' entire life cycles. They advocate for deleting exemptions for internal documents to allow for independent oversight.
Enhanced transparency would allow the group to verify the accuracy of safety assessments.
Chemical manufacturers may lose confidentiality over internal studies that must be shared.

Swedish Nature Conservation Society demands end to chemical secrecy

Swedish Society for Nature Conservation, 11 Aug 2022

SSNC requests the removal of legal obstacles to confidentiality and intellectual property rights. They advocate expanding the SCIP database and establishing global transparency standards for chemicals.
Accessing broader datasets would help the organization conduct thorough health risk assessments.
Manufacturers would lose protection for proprietary information through stricter confidentiality claim limits.

JBCE Demands Confidentiality Safeguards in EU Chemical Data Proposal

Japan Business Council in Europe, 2 Apr 2024

JBCE requests a system to prevent accidental release of trade secrets on common platforms. They suggest providing advance notice to companies before their information is made public.
Protecting trade secrets ensures companies avoid financial damage and maintain their competitive edge.

Federchimica Urges Trade Secret Protection for Chemical Data

Federazione Nazionale dell'Industria Chimica italiana, 27 Mar 2024

Federchimica requests high security for confidential information to protect industrial competitiveness. They demand that study notifications be limited to those with clear regulatory utility.
This would reduce administrative costs and prevent the relocation of research activities outside Europe.
Public authorities could lose early visibility into preliminary chemical screenings and innovative research methods.

Fragrance group urges stand-alone cosmetics safety body at ECHA

International Fragrance Association, 4 Apr 2024

IFRA demands the maintenance of the SCCS as a stand-alone safety body. They argue risk assessment must remain the primary decision-making process for products. The group also supports developing methods to further reduce animal testing.
Preserving a specialized body protects the industry's expert-driven risk assessment framework.

Cruelty Free Europe Urges Data Sharing to Stop Animal Testing

Cruelty Free Europe, 16 Aug 2022

The organization calls for increased data transparency and sharing to prevent redundant animal experiments. They insist that authorities must only commission animal testing as a final option after exhaustive data reviews. Furthermore, the Commission should prioritize the validation of non-animal testing methods within the regulatory framework.
Improved data accessibility would directly advance the organization's mission to eliminate animal testing across Europe.
Companies would lose competitive advantage as the proposal removes intellectual property protections for chemical data.

Polish cosmetics industry seeks clarity on chemical data platform

Polski Związek Przemysłu Kosmetycznego, 4 Apr 2024

The union requests clearer definitions for key terms and a precise scope for study notifications. They advocate for an exhaustive list of reportable studies and exemptions for research activities. Additionally, they stress that data sharing must respect the protection of proprietary information.
Specific exemptions and clearer rules would reduce compliance costs and protect trade secrets.

Polish cosmetics industry backs chemical data sharing initiative

Polski Związek Przemysłu Kosmetycznego, 16 Aug 2022

The organization supports the proposal to facilitate data flow across different stakeholder groups. They emphasize that transparency rules must respect data ownership and trade secrecy to avoid increasing administrative burdens.
The industry would benefit from reduced administrative burdens and simplified chemical reporting procedures.

Consultation response

The European Federation of Corrugated Board Manufacturers, 16 Aug 2022

The Packaging Inks Joint Industry Task Force (PIJITF), representing the packaging inks value chain, welcomes the European Commission’s intention to improve the availability of chemical data and exchange of information among the EU agencies. The PIJITF supports several initiatives proposed by…

Consultation response

Corbion, 12 Mar 2024

1. Avoid increased administrative burdens for business operators: The administrative burden on companies and the Agency has proven to be more time- and resource-intensive than initially anticipated. Not only the pre-submission phase but also the notification of studies should be proportionate and…

Consultation response

Stockholms universitet, 15 Aug 2022

Stockholm University welcomes and supports the Commission´s initiative for ‘one substance – one assessment’ and better access to chemicals data for safety assessments. Access to data is fundamental for health and environmental assessments and for the transition to a toxic-free circular economy.…

FEFANA warns chemical data platform will burden feed industry

FEFANA, 28 Mar 2024

The organization requests aligning the scope of studies with existing food law practices to avoid administrative friction. They call for a full impact assessment and consultation with industry experts before setting technical standards.
Harmonizing requirements would protect investment returns and prevent further delays in processing product applications.
Business operators face higher costs and more complex administrative processes under the current proposal.

FEFANA calls for caution on chemical data transparency

FEFANA, 16 Aug 2022

The group requests a thorough impact assessment to avoid excessive administrative burdens. They demand protection for confidential business information and fair compensation for data owners.
Industry would see lower costs through simplified procedures and less repetitive testing.
EU businesses suffer from processing delays and compromised returns on their investment.

Consultation response

Polish Association of Cosmetic and Detergent Industry / Polskie Stowarzyszenie Przemysłu Kosmetycznego i Detergentowego, 4 Apr 2024

Comments of the Polish Association of the Cosmetics and Detergents Industry on the legislative package "One substance, One assessment" -please refer to the attached document

Consultation response

Downstream Users of Chemicals Co-ordination Group, 4 Apr 2024

The Downstream User of Chemicals Coordination Group (DUCC), representing 11 European associations whose member companies use chemicals to formulate mixtures, provides the following response to the OSOA public consultation. DUCC supports the main objective of the OSOA approach under the Chemicals…

Consultation response

Downstream Users of Chemicals Co-ordination Group, 16 Aug 2022

The Downstream User of Chemicals Coordination Group (DUCC), representing 11 European associations whose member companies use chemicals to formulate mixtures raises the following with regards to the proposal of Commission to remove ‘improve access to chemicals data by removing technical and…

Ecofeminists urge open chemical data to speed up safety bans

Women Engage for a Common Future, 11 Aug 2022

WECF supports making existing chemical data easily accessible to accelerate evaluation processes and ban harmful substances. They advocate for including gender-differentiated data and using diverse sources, including academic research.
The proposal enables civil society to scrutinize decisions without facing lengthy administrative procedures.
Industry actors face faster product bans and continued pressure to provide detailed data.

Consultation response

Association of Manufacturers and Formulators of Enzyme Products, 4 Apr 2024

AMFEP, the representative association of manufacturers and formulators of enzyme products, welcomes the Commissions ambition to remove legislative obstacles for the re-use of data and better streamline the flow of chemical data between EU and national authorities, in line with the objectives of the…

Consultation response

European Precious Metals Federation, 16 Aug 2022

Please find in the attached file some generic comments on the proposal that EPMF generally welcome since the Precious Metals industry supports the concept of One Substance One Assessment (OSOA).

Consultation response

Beryllium Science & Technology Association, 5 Mar 2024

BeST welcomes the Commission's current initiative. It should be in the interest of all parties involved to have improved access to, and use of data for safety assessments. The proposals will impact the entire metals, minerals and chemicals sectors and we rely on Eurometaux and Cefic to address the…

Consultation response

PETA Science Consortium International e.V., 4 Apr 2024

PETA Science Consortium International e.V. welcomes the opportunity to contribute to the consultation 'Chemical safety better access to chemicals data for safety assessments', which includes the aim of establishing a common data platform for chemicals to ensure data findability, accessibility,…

Consultation response

Elanco Animal Health Incorporated, 16 Aug 2022

Elanco Animal Health welcomes the EU initiative towards a better access to chemicals data for safety assessment through simplification and reduction of administrative burden, while helping to minimize duplication of effort in data generation. In particular we support initiatives to compile publicly…

European Marine Board advocates big data approach for chemicals

European Marine Board, 2 Aug 2022

The board recommends adopting FAIR data principles and a big data approach for chemical assessments. They suggest developing community standards, standardized algorithms, and connecting with existing marine data networks.
This would optimize data use and improve management of chemical safety.

Consultation response

COSMED, 4 Apr 2024

COSMED, the French Cosmetic Association for SMEs, supports the main objective of the OSOA package. We however would like to draw attention on some key elements (definition, relevance of data, use of NAMs, study notification, confidentiality, access and use of data). Regarding the re-attribution of…

Consultation response

Huvepharma, 16 Aug 2022

We welcome initiatives that aim to harmonise rules, but notes these often raise the overall cost and impact by harmonising to the highest common denominator. The key points we would like to emphasise in this consultation are: 1. The need to support investment in R&D and innovation in the EU, to…

Consultation response

Deutsche Gesetzliche Unfallversicherung e.V., 16 Aug 2022

Die „Deutsche Gesetzliche Unfallversicherung“ (DGUV) bedankt sich für die bestehende Möglichkeit, zu der Konsultation zur chemischen Sicherheit – besserer Zugang zu Chemikaliendaten für die Sicherheitsbewertung einen Beitrag der gesetzlichen Unfallversicherung in Deutschland abgeben zu können. Die…

Consultation response

European Printing Ink Association, 16 Aug 2022

The European Printing Ink Industry Association (EuPIA) welcomes the opportunity to contribute to the initiative “Chemical safety – better access to chemicals data for safety assessments”, as the improved access to chemicals data originating from public authorities, private entities or scientific…

Consultation response

Polska Izba Przemysłu Chemicznego, 12 Aug 2022

Stanowisko PIPC znajduje się w załączonym pliku.

Consultation response

Japan Chemical Industry Association, 2 Apr 2024

Japan Chemical Industry Association (JCIA) appreciates the opportunity to provide the following comments in response to the proposal. JCIA respects the ambition of the European Chemicals Strategy for sustainability, which calls for the safe management of chemicals. Although we understand the…

Consultation response

Eurocolour e. V., 27 Mar 2024

Eurocolour welcomes the establishment of a common data platform to support sound scientific hazard and risk assessments. But there are still some areas of concern in the draft which we would like to elaborate on: Make best use of industries expertise: The establishment of the common data platform…

Consultation response

Rebutting Industry Science with Knowledge, 11 Dec 2023

Please see my 2-pg. pdf; thank you.

Consultation response

Bundesverband fuer Tiergesundheit, 16 Aug 2022

Der Bundesverband für Tiergesundheit (BfT) begrüßt im Grundsatz diese Initiative mit dem Ziel, einen besseren Zugang zu Chemikaliendaten für Sicherheitsbewertungen zu entwickeln. Insbesondere unterstützen wir Initiativen zur Zusammenstellung öffentlich verfügbarer Informationen und Bewertungen in…

Consultation response

European Manufacturers of Feed Minerals Association, 16 Aug 2022

Considering the period chosen for the present call, we would like to focus our input on one specific element: the need for an impact assessment. While the target of creating an open and common basis of data for various assessment through some convergence of different notification/authorisation…

Consultation response

ZOETIS, 16 Aug 2022

We welcome the objectives of this initiative with the goal to develop better access to chemicals data for safety assessments. We support to better streamline the flow of data on chemicals between different sector authorities/agencies (EU and national). We are however concerned about (unintended)…

Consultation response

European Centre for Ecotoxicology and Toxicology of Chemicals, 16 Aug 2022

ECETOC welcomes the opportunity to comment on this initiative, which would be a key step in the implementation of the “One Substance-One Assessment” action from the Chemical Strategy for Sustainability (CSS). Below you will find highlighted comments, more details can be found in the…

Consultation response

Afaïa, 12 Aug 2022

AFAÏA est le syndicat professionnel des acteurs de la filière des supports de culture, paillages, amendements organiques, engrais organiques et organo-minéraux et biostimulants. Représentant près d’une centaine de metteurs en marché de matières fertilisantes et intrants innovants des cultures…

Consultation response

Nanotechnology Industries Association, 12 Aug 2022

Please refer to the attached document.

Consultation response

Verband der Mineralfarbenindustrie e. V., 11 Aug 2022

This initiative is closely linked to the concept of ‘one substance, one assessment’, strived for under the EU Green Deal and its Chemicals Strategy for Sustainability. This concept promises some improvements in substance evaluation but at the same time it also harbours many pitfalls that might…

Senior Corporate Silver Spoon slams chemical safety data proposal

Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület, 21 Jul 2022

The association claims the proposal's legal basis is incorrect. They argue it ignores REACH regulations and uses inaccurate scientific terms.
This shift would prioritize the group's environmental engineering expertise in EU policy.
The public loses scientific rigor if the Commission ignores established environmental protection principles.

Consultation response

european consensus-platform for alternatives, 20 Jul 2022

This initiative is remarkable. Just one comment about:"create a data-generation mechanism for EU and national authorities and oblige industry and (external) testing laboratories to notify these authorities of any studies they commission, based on existing notification rules in the food sector.".…