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Proposal for a basic regulation of the European Chemicals Agency

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Current rules on the European Chemicals Agency (ECHA) date back to 2006.Since 2008, ECHA has been entrusted with new tasks deriving from various pieces of legislation and ad hoc agreements. This initiative provides the opportunity to strengthen the governance of ECHA and adapt it to its future role. The initiative will optimise and rationalise the working methods of ECHA bodies and increase the sustainability of its financing.

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Public consultation

ID: 13554

Lobbying Activity

55 responses

Environmental Bureau Urges Stronger Health Protection in ECHA Reform

European Environmental Bureau, 2 Dec 2025

The organization requests stronger focus on protecting human health and environment, increased committee capacity with stricter independence rules, and extended financial contributions from companies for ECHA services.
This would strengthen environmental protections and ensure vulnerable groups receive better safeguards from harmful chemicals.
Chemical manufacturers would face higher costs through increased fees and charges covering regulatory services.

Cefic demands transparency and data protection in ECHA reform

European Chemical Industry Council, 2 Dec 2025

Cefic requests full transparency for non-legally defined tasks and formal stakeholder participation. They advocate for the originator principle to prevent disclosure of confidential data. The group also insists industry fees must only fund their intended purposes.
These measures would safeguard proprietary information and prevent industry fees from funding unrelated activities.
Public interest groups lose access to chemical safety data due to stricter confidentiality rules.

Chemical Industry Seeks ECHA Governance Reforms and Predictable Funding

European Chemical Industry Council, 10 Oct 2022

Cefic requests that new ECHA tasks align with its mandate and receive proper resources before assignment. They want strengthened committee functioning, transparent processes, and coordinated regulatory measures. Any new fee mechanism should retain EU public funding, exclude evaluation processes, and avoid discouraging voluntary dossier updates.
This would maintain predictable costs and avoid fees becoming income-generation mechanisms.
Public interests lose if ECHA lacks sufficient independent funding for enforcement activities.

Consultation response

European Chemical Industry Council, 10 Oct 2022

EFCTC contribution to the Commission Public Consultation on the proposal for a basic regulation for the European Chemicals Agency INTRODUCTION The European FluoroCarbons Technical Committee is a Cefic Sector Group. Its main objectives are to provide up to date information about applications,…

EFPIA Urges Protection of Medicine Supply in ECHA Reform

European Federation of Pharmaceutical Industries and Associations, 7 Oct 2022

EFPIA demands the European Medicines Agency be consulted to align chemical rules with medical needs. They argue ECHA should not interfere with the risk-benefit assessments performed by the EMA. An impact assessment is requested to prevent shortages of chemicals used in healthcare.
This protects pharmaceutical supply chains and prevents new regulatory burdens on medicine manufacturers.
Patients face risks if new chemical rules restrict the availability of essential medicines.

SMEunited urges ECHA efficiency to limit SME bureaucratic burden

SMEunited aisbl, 10 Oct 2022

SMEunited wants ECHA to gain resources by optimizing administrative procedures. They also advocate for transferring resources saved by Member States to the agency.
Avoiding new costs helps SMEs manage the complexity of chemicals legislation.
Member States would see their budget resources shifted to the central agency.

ClientEarth Urges Stronger Independence Rules for EU Chemicals Agency

ClientEarth AISBL, 27 Nov 2025

The organization requests clarifying ECHA's mandate to protect sensitive populations, aligning conflict-of-interest rules with EFSA standards, and maintaining transparency provisions from REACH. They emphasize the most protective scientific opinion should prevail when agencies disagree.
This would strengthen environmental protections and ensure chemical safety decisions prioritize public health.
Chemical industry loses flexibility when agencies adopt the most protective scientific opinions on harmful substances.

ClientEarth urges ECHA to prioritize health over industry needs

ClientEarth AISBL, 10 Oct 2022

ClientEarth argues the agency should prioritize environmental protection and scientific excellence over industry interests. They also recommend updating expertise and tightening rules to prevent staff from joining industry lobbies.
This would ensure regulatory decisions align more closely with the NGO's environmental protection goals.
Chemical companies and lobby groups lose influence and the ability to hire former agency staff.

Eurogroup for Animals demands ECHA prioritize non-animal testing

Eurogroup for Animals, 10 Oct 2022

The group wants ECHA to formally promote non-animal testing methods to replace outdated safety assessments. They also suggest improving collaboration between agencies to synchronize data and expertise.
Institutionalizing these methods would directly advance their core mission of ending animal testing.
The general public remains at risk while the agency continues using outdated safety models.

Austrian business chamber demands efficiency and cost controls at ECHA

Wirtschaftskammer Österreich, 6 Oct 2022

Centralize tasks only where necessary to ensure efficiency and redirect resulting national savings to ECHA. The agency should optimize its administrative processes and undergo regular resource controls.
Efficient agency operations could prevent further bureaucratic and financial burdens on Austrian businesses.
Member states would see their national chemistry departments lose resources to the EU level.

Eurometaux backs ECHA governance reforms and single budget line

EUROMETAUX, 2 Dec 2025

The organization strongly supports introducing a single budget line to allow flexible resource management and reduce administrative overhead. They request broader expert nomination mechanisms, improved transparency in committee decisions through systematic documentation, and better coordination between Commission, Member States, and ECHA on dossier quality.
This would reduce their compliance costs and administrative burden while improving regulatory predictability.

Eurometaux calls for industry expertise and budget reforms in ECHA

EUROMETAUX, 10 Oct 2022

Eurometaux proposes delaying the regulation until chemical laws are revised to ensure efficiency. They want industry experts included and independent reviews of committee opinions.
Switching to EU budget funding would provide companies with financial predictability and stability.
Free-riding companies would lose their cost-sharing advantage through a registration token system.

L'Oréal urges ECHA to maintain independent cosmetics safety committee

L'Oréal, 10 Oct 2022

L'Oréal supports a stand-alone committee within ECHA for cosmetics. This ensures continued development of non-animal test methods and specific consumer exposure expertise.
A dedicated body avoids regulatory delays, ensuring new products reach markets faster.
Other chemical sectors face risks if the stretched Risk Assessment Committee takes on more work.

German Chemical Industry Calls for Greater Transparency and Industry Input at ECHA

Verband der Chemischen Industrie e.V., 27 Nov 2025

VCI requests mandatory direct dialogue between ECHA and affected companies, binding involvement of companies in committee meetings, and publication of substantial summary records instead of minimal final minutes. They also seek an appeals panel for committee opinions and a data owner forum.
This would reduce time and costs by preventing technically infeasible requirements and avoiding lengthy appeals.

European aerospace industry demands alignment between chemicals and safety rules

Aerospace, Security and Defence Industries Association of Europe, 10 Oct 2022

ASD requests a tighter partnership between ECHA and industry-specific bodies like EASA and ESA. They want a more coordinated approach to chemical regulations to prevent conflicting safety requirements.
This would prevent conflicting regulations from creating industrial deadlocks for aerospace companies.

German Steel Industry Warns Against Concentrating Chemical Agency Power

Wirtschaftsvereinigung Stahl, 10 Oct 2022

The industry opposes concentrating all decision-making authority within a single EU institution. They demand that socio-economic factors are fully integrated into the regulatory process.
This would prevent rising administrative costs and protect the industry's global competitiveness.

Cosmetics Europe supports ECHA reform, seeks to preserve independent safety committee

Cosmetics Europe, 2 Dec 2025

The organization supports moving the Scientific Committee for Consumer Safety to ECHA but insists it must remain a stand-alone committee with preserved independence, expertise, and procedures. They want the chairperson elected by members, not appointed, and explicit recognition of nanomaterials safety expertise. They also seek a stronger ECHA role in promoting non-animal testing methods.
This preserves their access to specialized cosmetics safety expertise while advancing non-animal testing methods.

Cosmetics Europe demands SCCS remain a standalone committee within ECHA

Cosmetics Europe, 10 Oct 2022

Cosmetics Europe insists the Scientific Committee on Consumer Safety must remain a standalone committee. This approach preserves specialized expertise and supports the continued development of non-animal testing methods.
Maintaining specialized committees ensures the industry remains competitive by avoiding slow review processes.
The European industry suffers if discontinued review processes hinder placing products on market.

AESGP demands ECHA reform respect health and food agency competencies

Association of the European Self-Care Industry, 10 Oct 2022

AESGP insists that ECHA's new responsibilities must not undermine the powers of agencies like EMA and EFSA. They also request a formal impact assessment to address potential effects on self-care products.
This prevents new financial burdens and maintains regulatory stability for manufacturers.
Scientific committees risk losing their established expertise through work transfers to ECHA.

Health Alliance backs stronger EU chemicals agency with expanded resources

Health & Environment Alliance, 1 Dec 2025

The organisation supports strengthening ECHA's governance and increasing its capacities. They request adding protection for vulnerable groups, aligning the proposal with the One Substance One Assessment approach, and fortifying the agency's independence.
This would enable ECHA to better protect health and environment through stronger scientific capacity.

HSI Europe urges ECHA to prioritize phasing out animal testing

Humane World for Animals Europe, 10 Oct 2022

HSI Europe recommends a formal mandate to promote non-animal methods and eventually phase out testing. They propose a new expert committee to guide the transition toward ethical safety assessments. Dedicated funding should support the development and regulatory use of these new approaches.
A formal mandate would cement their goal of ending animal testing.

HEAL backs ECHA reform and fees for non-compliant companies

Health & Environment Alliance, 6 Oct 2022

HEAL supports the proposal to ensure the agency handles its expanding workload. They urge the Commission to introduce fees for non-compliant registration dossiers. Fees for hazardous substances should also incentivize switching to safer alternatives.
This would strengthen the agency’s capacity to protect public health and the environment.
Non-compliant chemical companies would face higher costs through new administrative fees.

AnimalhealthEurope urges protection of veterinary medicine agency's role

AnimalhealthEurope, 10 Oct 2022

The group insists ECHA’s new powers must not overlap with existing medicine assessments. They demand that funding changes do not drain resources from medicines regulatory networks.
Preventing dual regulation ensures specialized oversight and reduces the risk of supply disruptions.

German Social Insurance Urges Worker Protection in EU Chemicals Agency Reform

Deutsche Sozialversicherung Europavertretung, 2 Dec 2025

The organization requests that occupational health and safety be explicitly anchored in the ECHA regulation, that worker protection experts be systematically included in committees and the management board, and that binding cooperation with EU-OSHA be established.
This would ensure worker protection perspectives systematically inform ECHA decisions on chemical safety.

German metal industry rejects higher fees for chemical agency

WirtschaftsVereinigung Metalle, 10 Oct 2022

WVMetalle demands that additional burdens and bureaucracy be avoided at all costs. They call for the correct implementation of the 'One Substance, One Assessment' concept. The association insists that ECHA's financing must remain a mix of fees and public funding.
This would protect metal companies from rising costs and new administrative requirements.
The EU public budget would bear more costs to ensure the agency's sustainability.

Essential oil federation demands independence for consumer safety committee

European Federation of Essential Oils, 2 Dec 2025

EFEO supports integrating the consumer safety committee if it retains its distinct identity and independence. They recommend that the committee’s mandate be broadened to include additional product categories. They also advocate for establishing an appeal system against agency opinions.
Independent oversight of safety assessments protects industry interests from potential conflicts within agency objectives.
Agency leadership loses the ability to integrate committee procedures or appoint staff to lead evaluations.

JBCE Urges Risk-Based Alignment in Chemical Agency Reforms

Japan Business Council in Europe, 10 Oct 2022

JBCE requests excluding substances not deemed hazardous under REACH from RoHS restrictions. They advocate for sector-based assessments where consumers lack direct exposure to internal parts. They also insist on maintaining the current methodology for evaluating product exemptions.
This would prevent new regulatory burdens and protect existing exemptions for manufacturers.
Environmental groups lose the ability to seek broader bans on chemicals in electronics.

Fragrance industry urges independent safety oversight and ECHA appeal mechanism

International Fragrance Association, 2 Dec 2025

Keep the cosmetic safety committee independent and focused on human health. Create an independent panel to allow legal challenges against agency scientific opinions. Strengthen the agency's role in promoting non-animal research and innovation.
Industry members could challenge chemical restrictions without filing expensive lawsuits in court.
Regulatory bodies may face delays in banning chemicals due to new objections.

Fragrance industry demands standalone committee for cosmetic safety

International Fragrance Association, 10 Oct 2022

IFRA demands the maintenance of a standalone expert committee for cosmetics safety. They support common hazard data but insist on sector-specific risk assessments. The industry strongly supports the continuation of the Scientific Committee on Consumer Safety.
Preserving specific risk assessment methods protects international trade and exports for fragrance companies.
Groups favoring a unified hazard-based approach lose influence over specific cosmetic safety evaluations.

Consultation response

Bundesverband der Deutschen Luft- und Raumfahrtindustrie e. V., 6 Oct 2022

The motivation for a basic regulation on the function and operation of ECHA and its bodies against the background of the Green Deal and the CSS is understandable. We thank you for the opportunity to contribute some basic comments on this matter. (1) ECHA and its bodies follow the principle of…

Cruelty Free Europe urges ECHA to prioritize non-animal testing

Cruelty Free Europe, 2 Dec 2025

The group demands ECHA establish an Expert Committee on non-animal approaches and provide mandatory staff training. They also propose formalizing NGO collaboration and requiring public justifications for any new animal tests.
This would institutionalize the transition away from animal testing within the agency’s core strategic planning.
Laboratories using traditional methods may face lower demand and stricter procedural requirements for animal tests.

Cruelty Free Europe urges ECHA to prioritize non-animal testing

Cruelty Free Europe, 10 Oct 2022

ECHA’s mandate should explicitly include promoting non-animal methods and transitioning from animal testing. They propose creating a dedicated expert body to maximize the use of alternative methods. They also advocate for mandatory training on non-animal data for regulatory decisions.
This would legally institutionalize animal welfare goals within the agency’s core operations.
Industry players would face increased financial pressure to fund these transition activities.

Polish cosmetics industry seeks independent safety committee within ECHA

Polski Związek Przemysłu Kosmetycznego, 10 Oct 2022

The Union requests keeping the Scientific Committee for Consumer Safety as an independent body. They argue sector-specific expertise is essential for reliable risk assessments of cosmetic ingredients.
Retaining a dedicated committee prevents slow review processes that hinder market access.
Consumers may face safety risks if specialized expertise in cosmetic exposure is lost.

German Animal Welfare Federation urges animal-free ECHA strategy

Deutscher Tierschutzbund - German Animal Welfare Federation, 2 Dec 2025

The federation wants ECHA to integrate animal-free testing into its structure and planning. They suggest directing financial resources toward modern non-animal methods and staff training. Additionally, they call for measurable milestones to track the transition away from animal testing.
This would directly advance the organization's core mission to end animal testing across Europe.
Traditional laboratories may face disruption as established animal testing methods are phased out.

Consultation response

Beiersdorf, 26 Nov 2025

As part of the European Commissions initiative to establish a Basic Regulation for the European Chemicals Agency (ECHA), we wish to express our strong support for maintaining the Scientific Committee on Consumer Safety (SCCS) as an independent, sector-specific expert body within the future…

Consultation response

Downstream Users of Chemicals Co-ordination Group, 2 Dec 2025

The Downstream Users of Chemicals Co-ordination Group (DUCC) welcomes the opportunity to contribute to this consultation. Please see the feedback attached.

Consultation response

Beryllium Science & Technology Association, 10 Oct 2022

Please find attached BeST's position paper.

Consultation response

Bundesverband der Deutschen Sicherheits- und Verteidigungsindustrie e.V., 10 Oct 2022

BDSV e.V. is the Federation of the German Security and Defence Industries and as such represents several companies that produce security and / or defence equipment in Germany. BDSV welcomes the opportunity to give input regarding the future workings of ECHA. 1) The future Basic regulation for ECHA…

Consultation response

Générations Futures, 2 Dec 2025

La proposition offre à l'ECHA un cadre juridique unique adapté à son mandat élargi. Des précisions supplémentaires sont nécessaires concernant ses objectifs, ses comités, sa coopération inter-agences, ses dispositions financières, son indépendance, sa transparence et une gestion rigoureuse des…

Consultation response

COSMED, 2 Dec 2025

COSMED welcomes the possibility to comment on the proposal which aims to strengthen the governance of ECHA. We fully understand the need to ensure the best use of expertise and resources of European agencies, however we stress that it is also essential to keep an efficient process ensuring a high…

Consultation response

COSMED, 10 Oct 2022

COSMED welcomes the possibility to comment on the proposal which aims to adjust the mandate and structure of ECHA. We embrace the objective of the CSS and fully understand the need to ensure the best use of expertise and resources of European agencies, however we stress that it is essential to keep…

Consultation response

Liebherr-Aerospace Lindenberg GmbH, 7 Oct 2022

Liebherr-Aerospace Lindenberg GmbH (LLI) is grateful for the opportunity to contribute some basic comments on the “Proposal for a basic regulation of the European Chemicals Agency”. 1. LLI is committed to the development of sustainable and environmentally friendly technologies, which is reflected…

Consultation response

Wirtschaftsverband der deutschen Kautschukindustrie e.V., 7 Oct 2022

Der wdk unterstützt die Chemikalienstrategie für Nachhaltigkeit der EU-Kommission und begrüßt, dass sie die Konsolidierung der Chemikalienregulierung sowohl zwischen den einzelnen Regulierungen wie z. B. REACH und der Trinkwasser-Richtlinie, als auch zwischen den Mitgliedsstaaten anstrebt. Vor…

Consultation response

Deutsche Gesetzliche Unfallversicherung e.V., 6 Oct 2022

Die „Deutsche Gesetzliche Unfallversicherung“ (DGUV) ist der Spitzenverband der gewerblichen Berufsgenossenschaften und der Unfallversicherungsträger der öffentlichen Hand. Er nimmt die gemeinsamen Interessen seiner Mitglieder wahr und fördert deren Aufgaben zum Wohl der Versicherten und der…

Consultation response

European Coalition to End Animal Experiments, 25 Nov 2025

This Regulation represents an important opportunity to ensure ECHAs additional tasks are fully aligned with the objectives of the Chemicals Strategy for Sustainability (CSS), Directive 2010/63/EU on the use of animals for research and testing and key commitments under the Commissions Roadmap…

Consultation response

The International Federation of Essential Oils and Aroma Trades Ltd, 2 Dec 2025

Please find attached the comments by the International Federation of Essential Oils and Aroma Trades (IFEAT)

Consultation response

, 2 Dec 2025

PPAM de France welcomes the opportunity to comment on the proposal and support its core aim of establishing a self-standing legal framework and stronger governance for the Agency. Beside this, we want to comment on the essential role of the Scientific Committee on Consumer Safety (SCCS) and to…

Consultation response

, 1 Dec 2025

Les modification proposées ayant une action sur les produits biocides notamment l'intégration du Comité d'analyse socio-économique (CASE) dans les processus d'évaluation et la simplification structurelle du texte vont dans le sens d'une régulation plus cohérente, capable de prendre en compte…

INDECOSA-CGT urges ECHA to prioritize health over industrial profits

Information et défense des consommateurs salariés – Confédération générale du travail, 1 Dec 2025

The organization demands that ECHA prioritize public health over economic interests and industrial lobbying. They call for immediate bans on dangerous chemicals rather than long, loophole-filled restriction processes.
Strict reforms would ensure better health protections for European consumers against toxic substances.
Chemical companies lose profits and face high costs for upgrading their production machinery.

Consultation response

Tronox Holdings plc, 10 Oct 2022

Tronox employs some 6,500 employees globally. Our diversity, unmatched vertical integration model, unparalleled operational and technical expertise across the value chain places Tronox as the global, leading titanium dioxide (TiO2) manufacturer. Tronox’s facilities in the Netherlands and France…

Consultation response

THE HELLENIC COSMETIC TOILETRY & PERFUMERY ASSOCIATION, 10 Oct 2022

We would like to thank the Commission for providing us with the opportunity to communicate our views on this important subject. Our Association fully supports the European Green Deal and the Chemicals Strategy for Sustainability and is committed to protect human health and the environment,…

Czech district heating association opposes higher chemical agency fees

Association for District Heating of the Czech Republic, 10 Oct 2022

ADH CR is fundamentally against increasing current fees or even introducing new ones. They propose seeking financial resources through internal savings and existing agency tools.
Avoiding new costs helps utilities maintain energy affordability during the sector's transformation.
Vulnerable households may suffer if fee increases lead to higher heating bills.

Consultation response

european consensus-platform for alternatives, 7 Oct 2022

The functioning of the European Chemical Agency is defined in Title II of REACH assigning the duty of “managing and in some cases carrying out the technical, scientific and administrative aspects of this Regulation and to ensure consistency at Community level in relation to these aspects” (Art.…

Consultation response

Detic asbl / vzw, 7 Oct 2022

Detic is the Belgian-Luxembourg association for producers and distributors of cosmetics, cleaning and maintenance products, adhesives and sealants, biocides and aerosols. Thank you for the opportunity to comment on the proposal for a basic regulation for EChA. Detic supports the comments made by…

Consultation response

Athena Cosmetics B.V., 6 Oct 2022

Athena Cosmetics welcomes the aims of the Proposal for a basic regulation of the European Chemicals Agency (ECHA) to simplify and clarify the rules under which ECHA operates – in light of the additional tasks entrusted to ECHA and the upcoming implementation of other legislation under the Chemicals…