Arnika, z.s.
Arnika
Our mission is to protect nature and a healthy environment for future generations both in Czechia and abroad.
ID: 854718349128-48
Lobbying Activity
Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
25 Mar 2025
Thank you for providing the opportunity to give feedback on the Taxonomy Delegated Acts. Arnika is a Czech non-governtal organization working on phasing out the most toxic substances from production, use and wastes by providing science-based arguments on toxic pollution worldwide since 2001. With great regret, we are following the deregulation activities of the European Commission. Our consumer campaigns reveal a strong support among EU citizens, including those from Central and Eastern Europe, for safe and toxics-free products and industrial processes. The current simplification proposal is a step back from the right direction on phasing out the Substances of Concern in groups to avoid regrettable substitution and lead to investments creating toxic pollution of the European environment as well as contributing to heatlh risks casued by thousands of chemicals with strong evidence for its toxic characteristics. Arnika prefers to inlcude also the Option 0 and keep the Appendix C as it is. For the options presented in the draft decision, Option 2 is at least to be adopted. In our experience, especially smaller companies with lesser market share do not have significant resources, investments and human capacities to invest into the research for truly non-toxic alternatives. The taxonomy would bring new incentives for research and knowledge share for implementing the "the DO NOT SIGNIFICANT HARM" principle in to the EU legislation. Majority of green certificates go beyond the SVHCs and constantly expand the list of restricred substances to ensure environmentally sustainable approach. Investors are warning against such deregulation initiatives that are likely to create legal uncertainty, jeopardise Europes long-term economic competitiveness and harm investment if rules are reopened for wholesale revision.
Read full responseResponse to Persistent organic pollutants - PBDEs
13 Mar 2025
ARNIKA is a Czech non-profit organization. Its Toxics and Waste Programme focuses on protecting people and the environment from toxic chemicals and promoting the use of safer alternatives. Arnika welcomes the proposal to gradually lower the unintentional trace contaminant (UTC) levels for PBDEs in recovered materials. Arnika shares the International Pollutants Elimination Network (IPEN) position to lower UTC limit further to 10 mg/kg and adopt this limit at an earlier stage to prevent the entering of legacy chemicals such as PBDEs back into recovered materials. However, we recognize that a compromise has been made and it is vital to adopt the decision proposed by the Commission as soon as possible to prevent the entering of plastics contaminated with higher PBDEs content back into the market. Many scientific papers reveal high levels of PBDEs contamination in black plastic recyclates used for consumer products including toys, hair accessories, office supplies and other consumer products although the contamination levels are gradually decreasing. The primary route of exposure is the accumulation of PBDEs in house dust. Additionally, when plastics with brominated flame retardants are recycled and heated to new plastic products, brominated and chlorinated dioxins are formed that further contaminate the recyclates while creating additional and very serious health risks for consumers and workers coming into contact with these materials. Therefore, we advise to strengthen the limit for all consumer products made of recovered materials as suggested for the exemption for children products. As children are exposed to other products than just those intended for children, we recommend to simplify the regulations and lower PBDEs UTC level to 10 mg/kg at an earlier stage as suggested for the exemption for children products ideally in 2026. As the EU Commission outlined its plan to boost Circular Economy in its Clean Industrial Deal stating that The Commission will adopt a Circular Economy Act in 2026, which will foster a higher supply of high quality recyclates and stimulate demand for secondary materials and circular products while bringing down feedstock costs, it is vital to decontaminate recovered plastics from the presence of PBDEs at the lowest possible levels, so that they are considered safe by consumers and downstream users for further use in products.
Read full responseMeeting with Veronika Vrecionová (Member of the European Parliament, Committee chair) and Greenpeace European Unit and Hnutí DUHA - Friends of the Earth Czech Republic
4 Dec 2024 · Future of CAP (incl. sustainable farming, pesticide management, animal welfare)
Response to Persistent organic pollutants - UV-328
26 Aug 2024
Arnika is a Czech-based non-governmental organization promoting strict restriction of harmful chemicals and has advocated for toxics-free materials and products for over 20 years. As an organization regularly investigating the contamination of products with POP chemicals and responding regularly to consumers' concerns about hazardous substances in articles including food contact materials and children's products, we have investigated the presence of UV stabilizers in daily used consumer products. We found a small number of products contaminated with UV-328 stabilizer in concentrations ranging from 0,00258 mg/kg (reusable coffee cup purchased in Czechia) and 0,238 mg/kg (gardening tools for children purchased in Czechia) to even 2200 mg/kg in water proof tape purchased in Austria. Several studies conducted in collaboration with the International Pollutants Elimination Network (IPEN) shows that UV-328 is widely detected in a range of consumer products around the world, as well as in recycled plastic pellets. An international study monitoring the contamination of plastic pellets collected from beaches around the globe found UV-328 in 101 of 110 (92%) of the plastic pellets collected at the beaches from 23 different countries. The average concentrations were relatively lower (below 50 ng/g) than other UV stabilizers detected in the same study (UV-327, UV-P, UV-326). Given the vast evidence in newly emerged hazard studies documented in the Risk Profile of UV-328 by POPRC in 2021, Arnika suggests a more stringent concentration limit for UV-328 that should be 0,1 mg/kg (0,00001 % by weight) in substances, mixtures, or articles. It is also clear that exemptions for UV-328 comes with a high risk for uncontrollable contamination of recycled plastics. In studies of hair accessories and toys from Russia, China, and Indonesia, all samples contained UV-328. The concentrations found in the 22 sampled toys ranged from 20 to 46 822 μg/kg, and between 272-984 μg/kg in the 6 sampled hair accessories. In a study of recycled plastic pellets purchased from 24 suppliers in 23 countries, samples from 17 suppliers in 16 countries contained UV-328 between 0.1 334 μg/kg. To ensure traceability and transparency for the exempted applications, Arnika suggests the introduction of a labeling system and/or the duty to track the imported products containing UV-328 via centrally managed databases. In view of increased recycling efforts in the EU, Arnika therefore proposes limiting any exemptions to only justified, essential uses. For applications where exemptions are justified, only shorter exemption periods should be granted to avoid continued contamination of recycled materials resulting in further obstacles for the recycling process in the sectors proposed for exemptions. Finally, an exemption for photographic paper seems completely unnecessary since the use of photographic paper has largely been replaced by digital imaging for both consumer and professional uses. Continuation of this use will lead to continued human and environmental exposure, including in remote locations such as the Arctic, even though it is avoidable.
Read full responseResponse to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials
5 Mar 2024
Arnika is a non-governmental organization promoting strict restriction of harmful endocrine-disrupting substances and has advocated for toxics-free materials and products for over 20 years. We welcome the proposal for revising the Food Packaging Materials legislation that includes the ban on Bisphenol A. We also appreciate the provisions to ban other bisphenols to prevent regrettable substitution. We encourage the Commission to include all the other bisphenols that meet the criteria for classification as CMRs and EDCs for human health of Category 2. As an organization working with consumers and responding regularly to their concerns about hazardous substances in food, packaging, and consumer products, we are often disappointed that food packaging contains several unregulated substances that leach into the food, water, and environment. In several surveys conducted as part of Life-funded projects, consumers voice their demand to ban these substances immediately. They are even surprised that substances recognized as harmful and classified as toxic to people are allowed in food packaging as well as other products. A recent analysis done by consumer associations from several EU countries led by BEUC revealed high levels of BPA and other bisphenols not only in a variety of children's products including baby bottles, sips and teething toys, children's sunglasses and textiles (see https://www.beuc.eu/blog/hormone-disrupting-chemicals-found-in-60-of-121-childrens-products/) but also in large concentrations in canned food and drinks. During the sampling organized by the Czech consumer association dTest in 2023, 50% of canned food packaging was free of bisphenols showing that alternatives are available on the market. Soft drinks in aluminum cans, on the other hand, were highly contaminated. At the same time, all of them had traces of BPA and BPF as well as other bisphenols in them and 70% showed some highest levels of bisphenols found in various consumer products. The entire report by dTest is available for downloading here: https://www.dtest.cz/clanek-10127/test-bisfenolu-ve-vyrobcich-pro-deti-2023 Last the HBM4EU initiative revealed that 92% of Europeans from 11 EU countries were contaminated with BPA residues in their urine, the legislators must act now and take all the measures to reduce the burden of such toxic endocrine disrupters contributing to severe health problems including increasing rates of infertility and breast cancer. In light of EFSA´s recent re-evaluation of the safety of BPA as used in FCMs from April 2023 when the tolerable daily intake levels were lowered 20,000 times, we strongly support the restriction that shall be adopted with no exemptions and for the entire class of bisphenols. By banning bisphenols (and ideally, PFAS and other unregulated toxic substances present in food packaging) the EU will contribute to creating materials cycles that are toxics-free and easier and safer for recycling or reuse. Concerning monitoring of contamination of recycled materials, the bisphenols migration from paper and board materials and articles containing recycled material should not be limited exclusively to BPA. The EU paper manufacturers have already substituted BPA with BPS. Therefore, it is likely that paper and board materials and articles containing recycled material are contaminated with BPS (already included in CLP regulation as a Reprotoxic 1B substance). Additionally, BPA can be found in recycled plastics. The Commission should ensure that contamination and migration of BPA and other bisphenols from plastic and paper food contact materials and articles containing recycled materials will not present a risk to the consumers. This submission is delivered as part of the project n. 101114078 LIFE22-GIE-HU-ToxFree LIFE for All where consumer associations from Hungary, Slovenia, Czechia, and Austria plus Arnika are working on raising awareness among consumers to change their behavior and choosing toxics-free products.
Read full responseMeeting with Alexandr Vondra (Member of the European Parliament, Shadow rapporteur)
10 Jan 2024 · Mercury + PFAS
Response to Revision of the Toy Safety Directive
27 Oct 2023
Arnika welcomes the revision of the Toy Directive while firstly agreeing with banning the new hazard classes of chemicals in toys including endocrine-disrupting and suspected endocrine-disrupting substances, respiratory sensitizers and STOTs (Specific Target Organ Toxicity). We propose to consider the ban of PBT substances that are also of a great health threat to children as they accumulate in their bodies and cause harm to their healthy development. We also support the ban on the use of bisphenol A, but we encourage its expansion to include all bisphenols, which should be covered by the EDC substances ban. The proposal suggests that the substances currently prohibited in products for children aged 0-3 should also be banned in toys for children of all ages. We fully support this. Arnika believes that the use of any toxic substances in toys is not essential and there are always alternatives or other design solutions to produce a toxics-free toy. ECHA shall be able to make exemptions but only if exposure from other products, sources, or the environment (combination effects) is considered in the assessments. Such derogations shall be always time-limited (up to 3 years) and the supplier or manufacturer has to provide explanation on why alternative technologies or materials are not available. The same process shall be applied if applications for extending the derogations are considered. Arnika supports the introduction of the digital product passport that shall contain information about chemical content for the benefit of consumers, retailers, and in waste management regarding circularity. It is important that the product passport does not require special apps but is free and easily accessible, for example, by scanning the barcode or QR code with the phone camera. Consumers and retailers wishing to avoid toxic substances exempted or not covered by this legislation should have a right to know if they are present in the toy. Consumers and retailers wishing to avoid these substances should be able to do so and the full transparency or full material declaration accessible via the digital product passport shall be the first step in this direction. It can also serve as a precedence for other types of consumer products. The proposal suggests that information on the toy's impact on the environment, or how it should be disposed of/recycled, can be included in the future. We would like to encourage this to be included immediately in the digital product passport. The regulation should include the possibility of holding online marketplaces accountable for non-compliant products if no other economically responsible party can be identified, or if the economically responsible party does not act appropriately and responsibly. Online marketplaces should also be obliged to verify the identity of the responsible person selling toys through their website. The transition period shall be shortened to 18 months. Arnika has written a number of studies showing the presence of PBT substances in toys, especially if made from recycled materials. We believe the solution is not to manufacture toys from recycled materials, but rather make sure that recycled materials are toxics-free. The first step is to ban all PBT substances as a class in toys. See more here: https://arnika.org/en/publications/toxic-soup-dioxins-in-plastic-toys https://arnika.org/en/publications/toxic-loophole-recycling-hazardous-waste-into-new-products
Read full responseResponse to Ensuring that hazardous chemicals banned in the European Union are not produced for export
26 Jul 2023
One of Arnika´s goals is to ban toxic chemicals globally. There is wide evidence about toxic substances contaminating people´s health globally. About 385 million cases of acute pesticide poisonings occur each year, mainly in low- and middle-income countries, where a large proportion of the population continues to be involved in agriculture or lives in areas where pesticides are used. In 2018 alone, more than 81,000 tonnes of pesticides containing 41 different hazardous chemicals banned on EU fields, have been exported from European factories for use in agriculture in other countries. It is quite astonishing that the EU companies are allowed to produce banned chemicals and pesticides for export to primarily middle and low-income countries. During Arnika´s collaboration with NGOs from Africa, South-East Asia and South America, Arnika brought evidence of inadequate implementation and control measures to ensure safe and environmentally sound practices in managing toxic chemicals, especially once they become waste. These countries are lacking resources and infrastructure to properly manage risks from using toxic chemicals and pesticides. Many recipient countries of banned pesticides and chemicals are also big exporters to the EU, which eventually causes the contamination of the EU citizens with these substances via imported foods and/or products. The European chemicals industry giants including Syngenta, Bayer and BASF are the world´s major producers and exporters of pesticides to the Low and middle income countries. (https://www.publiceye.ch/en/topics/pesticides/pesticide-giants-make-billions-from-bee-harming-and-carcinogenic-chemicals) Arnika strongly supports the option of banning the production and export of toxic substances including pesticides and restricted chemicals with no exemptions under the PIC directive. The export ban should apply regardless of whether the chemicals are exported as pure substances, or in mixtures or articles. A prohibition on the export of banned chemicals is an important first step, but it must be complemented by other measures. European manufacturers that make huge profits from the sale of hazardous, banned chemicals in low-and-middle income countries also produce a vast amount of those products outside Europe, the sales of which will remain unaffected by an EU export ban. Likewise, manufacturers could evade the export ban by moving production to other sites, outside the EU. Among the destinations for EU exports of banned chemicals are OECD countries such as the United States, Japan and Australia. An EU export ban should apply to all countries, including OECD members. Arnika therefore calls on the Commission to build upon this legislative initiative and complement the export ban of restricted substances with other global commitments and processes. For instance, the currently prepared ZERO draft of the Plastics Treaty should include a global ban on restricted substances in the manufacturing of plastics. The Commission should also itimplement without delay its commitment in the Chemical Strategy to promote due diligence for the production and use of chemicals within the upcoming initiative on sustainable corporate governance and clarify that agrochemical companies headquartered in the EU are prohibited from producing or selling dangerous chemicals that are banned in the EU anywhere in the world. Only a wide export ban of toxic chemicals with no exemptions will ensure that the future generations are not being poisoned by toxic legacy chemicals. See the Joint statement with more information here: https://corporateeurope.org/sites/default/files/2023-06/Joint-statement_EU-exports_1-december-2022.pdf
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
Arnika's mission is to promote environmental health, prevent toxic pollution within the European and global context. Arnika aims to eliminate the use and releases of POPs and other toxic chemicals in the Czech Republic as well as globally. Based on our experience with the contamination of consumer products and packaging with toxic substances, we sugget that the revised FCM legislation shall include a) All substances of high concern such as endocrine disruptors, PBTs, vPvB must be included in the Priority Group 1. In line with the Chemicals Strategy for Sustainability, the use and presence of such substances in FCM should be restricted to ensure the circular economy to become clean and sustainable. b) The FCM legislation shall take on the group/class approach. To prevent regrettable substitution, all chemicals in same group or class such as phthalates, PFAS, bisphenols, UV stabilizers shall be restricted from the start. It will ease the burden of public authorities and prevent companies from substituting with materials that prove to be harmful too. Prioritize restrictions of chemical groups rather than individual substances. (Arnika study showing the presence of PFAS in food contact materials: https://arnika.org/en/publications/throwaway-packaging-forever-chemicals-european-wide-survey-of-pfas-in-disposable-food-packaging-and-tableware) c) The legislation shall address mixture of chemicals because many chemicals are in FCMs and are migrating from FCMs. d) The FCM legislation shall apply the no data, no market principle. Business should be required to document the safety of their FCMs. e) Digital labelling must not replace on-product labels as the primary means of communicating information about FCMs to consumers. Doing so risks undermining, rather than enabling, informed consumer choices, e.g., by making access to information more time consuming and burdensome or by outright excluding some consumers from information essential to their health and well-being. Digital tools could however play an important complementary role. f) There shall be financial incentives to market reusable FCM to prevent the increase of waste volumes
Read full responseMeeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and
14 Mar 2023 · Implementation of the EU Chemicals Strategy for Sustainability and PFAS related measures
Meeting with Mikuláš Peksa (Member of the European Parliament)
26 Jan 2023 · Regulation of chemical substances