OpenLobby.EU
Explore

Introducing new hazard classes–CLP revision

Environment

Links

Public consultation

ID: 13578

Lobbying Activity

85 responses

Environmental Bureau Demands Stronger EU Chemical Hazard Classifications

European Environmental Bureau, 18 Oct 2022

The organization supports new hazard classes for endocrine disruptors and persistent chemicals but demands stricter science-based criteria. They want tougher cut-off values for mobile chemicals, inclusion of category 2 endocrine disruptors in toxicity assessments, and recognition of persistency as a standalone hazard class.
This would strengthen environmental protection and accelerate restrictions on harmful chemicals in consumer products.
Industry faces higher compliance costs and faster restrictions on currently used chemicals.

AmCham EU Urges Global Alignment on New Hazard Classes

American Chamber of Commerce to the European Union, 18 Oct 2022

AmCham EU requests that the Commission secures international support before implementing new hazard classes. They argue that vague definitions in the current proposal could undermine legal certainty.
This would prevent international trade barriers and reduce the cost of navigating conflicting regional regulations.
Environmental and health protections risk permanent delay if the EU waits for stalled international negotiations.

Chemical Industry Urges Delay in New EU Hazard Classifications

European Chemical Industry Council, 17 Oct 2022

Cefic requests that guidance be available before the delegated act enters into force, and calls for longer transition periods aligned with substances rather than mixtures. They want clarity on how to apply mobility criteria and other technical assessments. The industry argues the new classifications should align with the UN GHS process first.
This would reduce compliance costs and avoid duplicate labeling for EU and non-EU markets.
Public health and environmental groups lose faster implementation of protections against endocrine disruptors and persistent chemicals.

Pharma trade group warns CLP labels could disrupt medicine supplies

European Federation of Pharmaceutical Industries and Associations, 18 Oct 2022

The industry calls for hazard definitions based on causal relationships rather than correlation. They also propose consecutive transition periods to avoid supply chain disruptions for medicines.
Stricter evidence requirements and staggered timelines would lower their regulatory compliance costs.
Environmental groups lose as narrower hazard definitions make it harder to restrict chemicals.

ClientEarth urges faster implementation of new chemical hazard classes

ClientEarth AISBL, 17 Oct 2022

The group urges the Commission to shorten transition periods and introduce a specific pictogram for endocrine disruptors. They request broader evidence standards to ensure robust hazard classification. They also warn against specific provisions that could weaken the level of protection.
Stricter rules would help the organization use the law to ensure higher health and environmental protection.
Chemical manufacturers lose regulatory flexibility and face stricter requirements to label products as endocrine disruptors.

Eurogroup for Animals urges non-animal methods for chemical hazards

Eurogroup for Animals, 18 Oct 2022

The group calls for chemical classification to prioritize human data and non-animal methods over animal testing. They want animal studies used only as a last resort, with mandatory validation evidence for such trials.
This would legally mandate the group's mission to prioritize alternative research methods over animal testing.
Industry labs face higher hurdles to justify animal testing through new validation rules.

BASF urges clearer criteria and longer transitions for hazard classes

BASF SE, 18 Oct 2022

BASF requests precise legal definitions for new hazard classes to eliminate uncertainty. They advocate extending transition periods for mixtures to allow downstream users time to adapt. They also believe new classes should be introduced globally before being applied in Europe.
Longer transition periods and clearer definitions would prevent redundant workloads and reduce legal costs.
Public health and environmental groups lose if stricter evidence requirements delay chemical classifications.

Bayer urges flexibility in new EU chemical hazard classification rules

Bayer AG, 18 Oct 2022

Bayer requests alignment with existing EU definitions for endocrine disruptors and flexibility to use Weight of Evidence approaches for persistent and mobile substance classifications. They seek allowances for evidence showing adverse effects are not relevant to humans or populations.
This would allow them to avoid classifying chemicals where adverse effects lack human or environmental relevance.
Environmental and health advocates lose stronger protections against endocrine-disrupting and persistent chemicals.

Fuel industry urges UN approval before EU chemical hazard rules

FuelsEurope, 17 Oct 2022

FuelsEurope demands new hazard classes be discussed at UN-GHS level before EU implementation to avoid diverging from global standards. They request longer transitional periods of 36 months for substances and 48 months for mixtures, citing insufficient guidance and experience with new classifications.
This would preserve their global competitiveness and reduce compliance burdens from divergent standards.
Environmental and health advocates lose faster protection against persistent and toxic chemicals.

Danish industry urges global alignment on new chemical hazard classes

Confederation of Danish Industry, 18 Oct 2022

DI calls for hazard classes to align with international UN standards to protect competitiveness. They recommend adopting the WHO definition for endocrine disruptors and using validated data to avoid repeat studies.
The organization would avoid redundant testing expenses and gain legal certainty through clearer definitions.
Chemical users and regulatory bodies lose if safety communication becomes ambiguous or inconsistent.

FoodDrinkEurope urges risk-based approach for endocrine disruptor classification

FoodDrinkEurope, 14 Oct 2022

FoodDrinkEurope insists that identifying endocrine disruptors requires a causal link to an adverse effect in an intact organism. They argue against using labels for incomplete evidence like 'potential ED' and support standard risk analysis.
Industry avoids substance bans by ensuring chemicals are restricted only when exposure levels pose actual risks.
Environmental groups lose precautionary protections if regulators must prove exposure risks before banning chemicals.

Austrian Chamber of Commerce urges alignment with global chemical standards

Wirtschaftskammer Österreich, 14 Oct 2022

The Chamber opposes introducing new hazard classes through delegated acts rather than global standards. They request deleting the category for suspected endocrine disruptors to avoid vague classifications. Criteria for mobility must be clearly defined in the law to ensure legal certainty.
This would reduce regulatory uncertainty and protect products from being prematurely blacklisted.
Environmental groups lose protections against chemicals that spread rapidly through water supplies.

Eurometaux urges scientific clarity in new endocrine disruptor classifications

EUROMETAUX, 18 Oct 2022

Eurometaux requests removing the suspected category and requires proof of causality for classifications. They urge alignment with international standards and specific assessment frameworks for metals.
This prevents metals from being restricted due to secondary or non-specific biological reactions.

MedTech Europe urges alignment with UN standards on chemical labelling

MedTech Europe, 18 Oct 2022

The organization requests EU rules align with UN Globally Harmonized System to avoid regional labelling differences. They propose longer transitional periods: 36 months for substances, 48 months for new mixtures, and 60 months for existing mixtures. They argue changes should be part of core CLP review, not delegated acts.
This would reduce supply chain complexity and avoid maintaining separate regional product inventories.

CropLife Europe seeks consistency in new chemical hazard classifications

CropLife Europe, 14 Oct 2022

CropLife Europe strongly supports a Weight of Evidence approach for mobile substance classification. They encourage alignment with existing legal frameworks to promote consistency and the principle of one assessment. They also propose extending the transition period for mixtures to 60 months.
The organization would benefit from more predictable regulatory outcomes and lower administrative burdens.

Unilever urges EU to accept non-animal safety testing data

Unilever, 18 Oct 2022

Unilever requests that the EU fully consider the use of non-animal New Approach Methodologies in chemical safety assessments. They argue the law should ensure the most relevant science is used so that animal testing is always a last resort.
Unilever would leverage their extensive internal expertise in non-animal safety assessment methodologies.
Traditional animal testing facilities would lose their status as the primary source for safety data.

Deutsche Umwelthilfe backs new hazard classes for persistent chemicals

Deutsche Umwelthilfe e.V., 18 Oct 2022

The group strongly supports new hazard classes to protect human health and environment. They specifically call for classifying Trifluoracetate to protect drinking water quality. They also demand the Commission accelerate the restriction of persistent chemicals through REACH.
These changes would allow better communication of risks and trigger better control measures.
The chemical industry would face new costs associated with stricter chemical management.

Consultation response

Verband der Chemischen Industrie e.V., 17 Oct 2022

Further information in the attached document General comments -No need for new CLP hazard classes: The introduction of new hazard classes is not necessary. A high level of health and environmental protection and improvement of environmental quality are already provided by existing legislation.…

Zero Waste Europe backs new chemical hazard categories

Zero Waste Europe, 18 Oct 2022

Zero Waste Europe supports adding hazard classes for hormone disruptors and persistent chemicals. They want these classifications to automatically trigger bans on using such chemicals in consumer products.
Stronger chemical regulations help the group achieve its vision for a toxic-free environment.
Chemical manufacturers face market bans for products containing newly classified hazardous substances.

Cosmetics Europe urges non-animal testing in chemical safety rules

Cosmetics Europe, 18 Oct 2022

The organization wants the EU to include modern non-animal testing methods as supporting evidence for all chemical classifications. They propose a harmonized framework to ensure that animal testing is strictly used as a last resort.
Adopting these methods would allow the industry to avoid the costs and delays of animal testing.

PAN Europe demands stricter labels for hormone-disrupting chemicals

Pesticide Action Network Europe, 17 Oct 2022

They support new hazard classes but demand a shorter transition period for better protection. The group requests pictograms for all classes and clearer warnings about risks to children.
Faster implementation helps the group achieve its main goal of a toxic-free environment.
Chemical manufacturers would face tighter deadlines and more complex requirements for their products.

ETRMA Urges Flexible Hazard Rules For Rubber Mixtures

European Tyre & Rubber Manufacturers' Association, 17 Oct 2022

ETRMA requests flexible classification rules that account for chemicals trapped within rubber matrices. They also seek specific guidance and longer transition periods for mixtures.
Tailored rules would prevent rubber products from being inaccurately labeled as hazardous mixtures.

Copper industry urges EU consistency with global chemical standards

International Copper Association Europe, 17 Oct 2022

The group wants EU chemical labels to match international standards for global trade. They request that endocrine disruptor definitions require evidence of direct causal effects. They also argue against applying new hazard criteria to inorganic metals.
The industry avoids the high costs of reclassifying products during international trade.
Environmental groups lose earlier health protections as the industry prioritizes global consensus.

CEO urges stronger labeling for endocrine disruptors and toxins

Corporate Europe Observatory, 14 Oct 2022

The organization requests dedicated pictograms and improved hazard statements for new chemical classes. They recommend keeping transition periods as short as possible to protect users quickly.
Public health advocates would see improved hazard communication for consumers and safer conditions for workers.
Industry players would face new restrictions and stricter requirements for persistent chemical products.

Consultation response

Humane World for Animals Europe, 18 Oct 2022

HSI/Europe welcomes this opportunity to comment on this initiative. Please refer to our comments attached.

CHEM Trust urges faster rollout of chemical hazard classes

Chemicals, Health and Environment Monitoring Trust, 18 Oct 2022

The group supports the introduction of new hazard classes but calls for shortening transition times. They argue application times should be changed to 12 months for substances. They also suggest broader criteria to prevent persistent water contaminants from falling through the net.
These changes would help the group protect human health and ensure transparency in supply chains.
Chemical manufacturers would face higher costs and tighter deadlines for reclassifying and relabeling their products.

Health group HEAL urges swift adoption of new hazard classes

Health & Environment Alliance, 13 Oct 2022

HEAL demands the rapid introduction of hazard classes for endocrine disruptors and persistent chemicals. They advocate for shorter transition periods and alignment with existing scientific guidance. The group also requests clear pictograms and hazard statements including impacts on future generations.
Stronger regulations help the organization achieve its mission of protecting public health.
Chemical manufacturers would face stricter labelling requirements and tighter deadlines for market compliance.

EIA supports adding toxic mobile chemicals to EU regulations

Environmental Investigation Agency, 18 Oct 2022

The group supports including persistent, mobile, and toxic substances as new hazard classes. This move would protect consumers and help reach zero chemical pollution.
Stricter classifications provide the regulatory foundation needed to achieve the group's environmental goals.
The automotive industry faces future scrutiny as chemicals in car air-conditioning contribute to pollution.

H&M Group Backs New EU Chemical Hazard Classifications

H M Hennes Mauritz AB, 13 Oct 2022

H&M Group supports adding new hazard classes to increase transparency in supply chains. They argue these rules are necessary to identify and replace hazardous chemicals more quickly.
Better access to information helps the company design safer and more circular products.
Producers of substances like endocrine disruptors face new restrictions and potential market bans.

EurEau backs new hazard classes to protect drinking water

European Federation of National Associations of Water Services, 18 Oct 2022

EurEau supports classifying persistent and mobile substances as hazardous to facilitate their phase-out under REACH. They advocate for stricter mobility criteria and banning industrial discharge of these chemicals into urban sewers.
Stricter source controls reduce the presence of hard-to-remove chemicals in drinking water resources.
Industrial companies would face bans on releasing specific hazardous substances into sewer networks.

Henkel warns against EU deviating from global chemical standards

Henkel AG & Co. KGaA, 18 Oct 2022

Henkel requests that the EU align with global standards to prevent international disharmonization. They argue that transition periods should only start after adequate guidance is available. Additionally, industry experts should participate in drafting these guidelines to share practical experience.
This would avoid regulatory uncertainty and allow sufficient time for complex label and formula changes.
Environmental groups lose timely protections if the EU delays introducing hazard classes for endocrine disruptors.

ChemSec demands stricter rules and faster labeling for hazardous chemicals

International Chemical Secretariat, 18 Oct 2022

ChemSec calls for more stringent criteria and significantly shorter transition periods for labeling hazardous substances. They argue the current five-year delay for mixtures hides vital safety information from consumers.
This accelerates the identification of hazardous substances to achieve a toxic-free environment.
Chemical producers would have less time to comply with more stringent classification requirements.

Green Transition Denmark Backs New EU Chemical Hazard Rules

Rådet for Grøn Omstilling, 17 Oct 2022

The organization supports the new hazard classes but demands a dedicated consumer pictogram for endocrine disruptors. They also want hazard statements to explicitly mention risks to future generations.
This proposal would achieve a higher level of protection for human health and the environment.
Chemical producers face stricter labeling requirements and increased public scrutiny of their products.

Solvay Demands Scientific Clarity in New EU Chemical Hazard Rules

Solvay SA, 14 Oct 2022

Solvay requests that endocrine disruption definitions focus on population-level impacts rather than individual organisms. They also recommend that mobility assessments use a broad evidence-based approach instead of simple screening values.
This would help the company avoid broad hazard classifications that they consider scientifically unjustified.
Environmental protections for individual animals could be weakened by focusing only on population-wide harm.

Consultation response

Swedish Society for Nature Conservation, 18 Oct 2022

Swedish Society for Nature Conservation (SSNC) comments on the Commission’s proposal for an Amending Regulation (EC) No 1272/2008 as regards adding new hazard classes and criteria for CLP General comments SSNC strongly recommend inclusion of the new hazardous classes, as proposed in the…

Essential oil industry seeks clearer rules for endocrine disruptors

European Federation of Essential Oils, 18 Oct 2022

EFEO requests clear definitions for endocrine disruptors incorporating irreversibility and the use of modern testing methods. They also advocate for higher concentration limits and delayed implementation until comprehensive guidance is released.
This would prevent essential oils from being unfairly classified and lower technical compliance burdens.
Consumer safety groups may see weaker standards and significant delays in chemical hazard reporting.

Japanese industry urges EU chemical rules to align globally

Japan Business Council in Europe, 17 Oct 2022

JBCE calls for consistency with international standards to prevent global supply chain confusion. They suggest that new hazard criteria require scientific consensus and clear implementation guidance prior to adoption.
This would reduce the massive costs and resources required to reclassify and relabel products.
Global supply chains face disruption and environmental sustainability is harmed by unnecessary packaging waste.

Italian Chemical Industry Urges UN Alignment on Hazard Classes

Federazione Nazionale dell'Industria Chimica italiana, 18 Oct 2022

The federation requests that new hazard classes be adopted internationally before implementation in the EU. They also call for clear technical guidance and longer transition periods for testing and software updates.
Global alignment would prevent the administrative burden of repeatedly updating product labels and safety documents.
Downstream sectors and consumers may lose access to products due to a regulatory ripple effect.

CNRS urges clearer hazard labels and stricter chemical rules

Centre National de la Recherche Scientifique, 18 Oct 2022

CNRS requests clearer definitions of adverse effects and the addition of hazard pictograms on labels. They advocate for including more cancer-causing substances and updating testing requirements to ensure data quality.
Improved safety information would help researchers manage chemical risks and prevent workplace accidents.
Chemical producers would face higher costs from mandatory safety tests and updated packaging requirements.

Consultation response

IKEM - Innovations- och kemiindustrierna i Sverige AB (556865-4650), 18 Oct 2022

IKEM – Innovation and Chemical Industries in Sweden – thanks the Commission for the possibility to comment on the draft delegated act for new hazard classes in CLP. We wish to put forward the following comments in the attached document.

Fragrance association urges clear rules and global chemical alignment

International Fragrance Association, 18 Oct 2022

The industry requests clearer legal definitions for new hazard classes to ensure consistency and legal certainty. They want transition periods to be based on the publication of guidance rather than the regulation itself. Finally, they urge the Commission to align these rules with global standards before implementation.
This would reduce the risk of non-compliance and avoid costly, repetitive label updates.
Environmental advocates lose timely protections against chemicals that potentially contaminate vital water resources.

Cruelty Free Europe urges EU to prioritize non-animal testing

Cruelty Free Europe, 18 Oct 2022

The group calls for future-proofing the CLP regulation by removing barriers to non-animal data. They request mechanisms to keep rules updated with the latest scientific advances. They also want the European Chemicals Agency to support industry in using non-animal information.
This shift would reduce reliance on animals while improving chemical assessment accuracy.

Endocrine Society urges broader definitions for endocrine disruptor classification

Endocrine Society, 18 Oct 2022

The Society requests aligning definitions with the WHO to ensure all endocrine alterations are captured. They also recommend removing concentration limits for mixtures, arguing there are no safe exposure thresholds.
Stricter classifications would help the organization achieve its mission of minimizing exposure to hazardous chemicals.
Chemical companies would lose the ability to market mixtures containing low-level endocrine disruptors without labels.

Consultation response

Agence nationale de sécurité sanitaire de l'alimentation, de l'environnement et du travail, 13 Oct 2022

Please find attached the FR-ANSES opinion. The opinion is in french and the annex in english.

Portuguese NGO ZERO urges faster implementation of endocrine disruptor rules

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 17 Oct 2022

ZERO requests rapid implementation of the new hazard classes, addition of pictograms for endocrine disruptors and persistent substances, and improved hazard statements. They argue the long transition period puts public health at risk.
This would increase transparency and help citizens identify hazardous chemicals in products.

Consultation response

LANXESS AG, 17 Oct 2022

As the EU Commission has stated several times “the CLP Regulation is the core piece of Union legislation for the hazard assessment of chemicals, stemming from the United Nations’ global standard (GHS), and sets out the hazard classification of chemicals and how to communicate those hazards to…

Consultation response

Alzchem Trostberg GmbH, 18 Oct 2022

Alzchem Trostberg GmbH does not support the introduction of the new CLP hazard classes because of the following reasons : - EU CLP should be aligned with the UN GHS process before before implementation not vice versa, this contradicts the approach of the harmonized classification system all…

Coatings industry warns new hazard classes harm global competitiveness

European Council of the Paint, Printing Ink and Artists' Colours Industry, 17 Oct 2022

The industry requests alignment with global rules to avoid significant deviation from consensus-based standards. They call for clearer scientific criteria and adequately long transitional periods for mixtures. CEPE also questions using delegated acts to implement changes of this magnitude.
Maintaining current standards would protect the pool of suitable raw materials for industry.
Environmental groups lose the ability to quickly restrict chemicals linked to endocrine disruption.

CIEL urges faster classification and clearer labels for endocrine disruptors

Center for International Environmental Law, 18 Oct 2022

CIEL demands a shorter transition period and new visual symbols to identify endocrine-disrupting chemicals. They also propose technical wording changes to allow broader scientific evidence in classifications.
Faster implementation helps CIEL fulfill its goal of protecting vulnerable groups from hazardous chemical impacts.
Chemical companies would face tighter deadlines and more restrictive labeling requirements for their products.

German paint industry opposes new EU chemical hazard classes

Verband der deutschen Lack- und Druckfarbenindustrie e. V., 14 Oct 2022

The association suggests new hazard classes should first be defined at the international level. They argue existing laws are sufficient to identify and regulate endocrine disruptors. They fear the proposal creates excessive bureaucratic burdens for medium-sized businesses.
This prevents automatic bans on up to two-thirds of the industry's raw materials.
Health and environmental groups lose a mechanism for the fast-track removal of hazardous substances.

Consultation response

Union of the European Lubricants Industry, 18 Oct 2022

The Union of the European Lubricants Industry (UEIL) and the Technical Association of the European Lubricants (ATIEL) have joined forces to comment on the call for evidence on the draft CLP delegated act for new hazard classes (ED, PBT/vPvB, PMT/vPvM). The undersigned associations welcome the…

FEFANA urges EU to align chemical rules with global standards

FEFANA, 17 Oct 2022

FEFANA requests that the EU avoids introducing new hazard classes unilaterally. They want the EU to seek inclusion in global standards first.
Maintaining alignment with global standards protects the competitiveness of EU operators.
EU businesses risk international isolation if the EU acts without global consensus.

Consultation response

Downstream Users of Chemicals Co-ordination Group, 18 Oct 2022

DUCC, representing 11 EU industry sectors who use chemicals to formulate mixtures, thanks for the opportunity to comment on the draft delegated act for new hazard classes (ED, PBT/vPvB, PMT/vPvM). As a horizontal legislation CLP has wide-ranging impact, with knock-on effects on other legal…

Consultation response

European Flavour Association, 18 Oct 2022

See attached file

WECF demands faster bans on endocrine disrupting hazardous chemicals

Women Engage for a Common Future, 17 Oct 2022

WECF calls for reducing the implementation timeline from 42 to 18 months. They want gender-differentiated data included and hazardous chemicals banned from consumer products. Furthermore, they demand easily understandable danger pictograms on all products containing these substances.
This accelerates their mission to protect women and workers from toxic exposure.
Chemical manufacturers would face much shorter deadlines to comply with new labeling rules.

Consultation response

European Precious Metals Federation, 18 Oct 2022

The European Precious Metals Federation (EPMF) welcomes the opportunity to comment on the draft delegated act amending Regulation (EC) n° 1272/2008 as regards hazard classes and criteria for the classification, labelling and packaging of substances and mixtures. Please find here below our comments…

Spanish Chemical Industry Urges Global Alignment on Chemical Rules

FEDERACIÓN EMPRESARIAL DE LA INDUSTRIA QUÍMICA ESPAÑOLA, 18 Oct 2022

Feique requests aligning new hazard classes with international standards and providing technical guidance before enforcement. They argue for longer transition periods to facilitate the re-labeling of chemical mixtures.
Aligning with global standards would reduce administrative burdens and prevent market confusion.
Consumers and professionals face losing access to essential chemical products.

Consultation response

PETA Science Consortium International e.V., 18 Oct 2022

PETA Science Consortium International e.V. ('the Science Consortium') is grateful for the opportunity to comment on the draft Commission delegated regulation amending Regulation (EC) No 1272/2008 as regards hazard classes and criteria for the classification, labelling and packaging of substances…

Consultation response

Koninklijke Vereniging van de Nederlandse Chemische Industrie, 18 Oct 2022

Zienswijze van de VNCI met betrekking tot het initiatief van de EU Commissie om nieuwe gevarenklassen te introduceren bij de CLP-herziening. De voorgestelde wettekst over het toepassen van nieuwe gevarenklassen in CLP is nog onvoldoende duidelijk. Daarnaast is het essentieel dat er tijdig, dat…

Consultation response

ERM Coalition, 14 Oct 2022

The ERM Coalition strongly supports the proposed Delegated Regulation of the Commission to amend the CLP Regulation and include PMT and vPvM substances as new hazard classes. This is an overdue milestone to protect human health from their unpredictable, long-term, toxic effects. We very much…

Consultation response

International Pollutants Elimination Network, 13 Oct 2022

Arnika - Toxics and Waste Programme welcomes the draft proposal for new hazard classes in the annexes of the CLP regulation. Arnika published numerous studies about the pollution of water, soils and especially products and wastes including those intended for recycling or further use with…

Consultation response

shecco, 18 Oct 2022

Dear Policy Officers at DG ENVI, Shecco/ATMOsphere welcomes the possibility to comment on the updates of rules on classification, labelling and packaging for hazardous chemicals. Shecco/ATMOsphere is a market accelerator of energy-efficient refrigeration, air-conditioning and heat pumps (RACHP)…

Consultation response

COSMED, 18 Oct 2022

COSMED and the Essential Oil Consortium thank the European Commission for the opportunity to provide comments on the draft act, which introduces new hazard classes and criteria for classification, labelling and packaging in the regulation (EC) N°1272/2008. Our position regarding the definition and…

Consultation response

Comité Interprofessionel des Huiles Essentielles Françaises, 18 Oct 2022

CIHEF and PPAM de France welcome the opportunity to provide comments on the draft act, which introduces new hazard classes and criteria for classification, labelling and packaging in the regulation (EC) N°1272/2008. CIHEF and PPAM de France made comments mainly regarding the introduction of the…

Consultation response

Health and Environment Justice Support, 17 Oct 2022

HEJSupport welcomes the draft proposal of the EU Commission for new hazard classes in the annexes of the CLP regulation and the draft criteria for ED identification. The proposal reflects the goals of the CSS and leads to better prevention and minimization of EDC exposure. Many studies show that…

Consultation response

European Society of Endocrinology, 18 Oct 2022

The European Society of Endocrinology (ESE) welcomes the ambition of the Commission to create a non-toxic and safe EU environment as laid out in the Chemical Strategy for Sustainability. ESE has continuously pointed to the growing importance of appropriate legislation and guidance on classifying…

Consultation response

Ecological and Toxicological Association of Dyes and Organic Pigments Manufacturers, 18 Oct 2022

Please see attached file.

Consultation response

Polska Izba Przemysłu Chemicznego, 18 Oct 2022

Stanowisko PIPC znajduje się w załączonym pliku.

Consultation response

European Coalition to End Animal Experiments, 14 Oct 2022

The need to use non-animal methods to the maximum possible extent and to transition away from testing on animals is clear. The End Animal Testing European Citizens Initiative (www.endanimaltesting.eu), which recently closed with 1,413,383 signatures, calls on the Commission to transform EU…

Stockholm University supports new EU chemical hazard classes

Stockholms universitet, 14 Oct 2022

The university supports the new hazard classes but recommends refining criteria for persistence and bioaccumulation. They suggest using sediment-water mixtures and incorporating modern animal-free assessment methods.
Scientifically accurate criteria ensure regulators can effectively prioritize and restrict the most problematic chemicals.
Animal welfare interests are harmed as outdated criteria increase the need for animal testing.

Consultation response

, 18 Oct 2022

The European Society for Paediatric Endocrinology (ESPE) is an international society based in Europe that promotes the highest levels of clinical care for infants, children and adolescents with endocrine problems throughout the world, including in less advantaged areas. Within the merit of its…

Consultation response

SYNDICAT NATIONAL DES INGREDIENTS AROMATIQUES ALIMENTAIRES, 18 Oct 2022

Please see the contribution attached.

Consultation response

Associação Portuguesa da Química, Petroquímica e Refinação, 18 Oct 2022

Considerando a revisão do Regulamento CLP em curso, assim como a proposta concreta de Regulamento Delegado de alteração ao CLP disponibilizada no presente processo de consulta, a APQuímica – Associação Portuguesa da Química, Petroquímica e Refinação vê com agrado esta oportunidade de poder…

Consultation response

Aqua Europa, 18 Oct 2022

We reject the contemplated implementation of new hazard classes without alignment with the UN-GHS regime. Activities on the introduction of new hazard classes must be done under the leadership of UN GHS and OECD. The Commission’s proposal, therefore, does not contribute to the goal of achieving…

Consultation response

Vereniging van Rivierwaterbedrijven, 18 Oct 2022

RIWA welcomes the Commissions' proposal for the additional hazard classes to be included in the amendment of the CLP regulation (EC) No 1272/2008, including EDC, PBT, vPvB, PMT and vPvM. We believe that introducing the PMT/vPvM hazard categories in the CLP will provide net benefits for Europe.…

Consultation response

TOBACCO AND NICOTINE PRODUCTS CHEMICALS GROUP, 18 Oct 2022

See attached.

Consultation response

European Centre for Ecotoxicology and Toxicology of Chemicals, 18 Oct 2022

ECETOC welcomes the opportunity to comment on the proposed inclusion of the new hazard classes, including for substances considered as persistent, mobile and toxic (PMT), and/or very persistent and very mobile (vPvM), by amending Regulation (EC) No 1272/2008 as regards hazard classes and criteria…

Consultation response

Global Action in the Interest of Animals, 17 Oct 2022

GAIA vraagt dat proefdiervrije testmethoden worden toegepast en dat het gebruik van dierproeven wordt uitgefaseerd. Om de afbouw van dierproeven te realiseren moeten resultaten uit reeds uitgevoerde proeven zo uitgebreid en optimaal mogelijk worden ingezet om informatie over chemische stoffen te…

Consultation response

european consensus-platform for alternatives, 17 Oct 2022

Regarding the “Draft delegated regulation - Ares(2022)6485391”, the whereas section should contain the following sentence: “The guidance on the application of the endocrine disruptor criteria should consider the applicability of New Approach Methodologies (NAMs), including in this term in silico,…

Consultation response

Verband Chemiehandel e.V., 17 Oct 2022

VCH Position on „Hazardous chemicals – updated rules on classification, labelling and packaging“ We thank the Commission for the oppertunity to provide our comments concerning the Commission proposal for a delegated regulation amending the CLP Regulation. Please find our position in the attachment.

Consultation response

European Federation for Construction Chemicals, 17 Oct 2022

The European Federation for Construction Chemicals (EFCC) welcomes the opportunity to participate in the public consultation on CLP Delegated Act for new hazard classes. EFCC members consider ensuring the protection of citizens and the environment against hazardous chemicals important, however,…

Consultation response

Japan Chemical Industry Association, 17 Oct 2022

JCIA has repeatedly requested that the new hazard classes be discussed first in the UN GHS. Even if the CLP introduces the new hazard classes prior to the UN GHS, we hope that the impacts on the global supply chain, including products necessary to build a sustainable society in Europe, will be…

Consultation response

Verband der Mineralfarbenindustrie e. V., 17 Oct 2022

In course of the EU’s Green Deal and the Chemicals Strategy for Sustainability, both the CLP and the REACH Regulation, EU’s fundamental chemicals’ regulations, shall be revised. The Commis-sion’s aim is to further improve human health and the protection of the environment by providing a legal…

Consultation response

Rebutting Industry Science with Knowledge, 30 Sept 2022

I thank the Commission for this initiative; I also urge the creation of sufficient EDC hazard classes (e.g., 'proven, suspected & potential'). While industry is correct that different species respond differently to EDCs, I am unsure that there is a need to keep the often-artificial distinction…

Consultation response

Gustaaf Bos Consulting, 28 Sept 2022

After having participated in EFSA’s “oneEU2022” and in the “2022 4th Annual Forum on Endocrine Disruptors” I am convinced it is not only very important to know if a chemical is either ‘an endocrine disruptor with adverse effects on human health or with adverse effects on the environment’, and to…