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CETS - European Committee for Surface Treatment aisbl

CETS

CETS was established in 1981 with the prime objective to provide the facility of European manufacturers of surface treatment plants and processes to share common needs of: • Exchange of knowledge on health, safety and environmental issues • Exchange of information on matters of statutory regulations • Exchange of information on business statistics • Aspire an European standardization • Observe market development and sales statistics • Accomplish market research CETS also encourages dialogue between the process suppliers and their customers, and provides a forum where the national associations within Europe can debate and exchange information on common issues. The CETS forum also provides the focal point for contact between the European surface engineering industry and the European Commission. Members of CETS manufacture and operate plants and processes for: • Chemical and electrochemical treatment of metal and plastics • Physical and thermal metal coating • Ancillar (...)

Lobbying Activity

Meeting with Mohammed Chahim (Member of the European Parliament, Shadow rapporteur)

2 May 2023 · IED

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

21 May 2021

The CETS lists its key conclusions here, detailed justifications for the conclusions can be found in the attached document Key Comments: - A toxic-free environment is a fantasy as there are many naturally occurring toxic organisms and substance in the environment already. CETS considers it questionable to establish such an approach as a basis for decision-making. - The further accumulation of unspecified and unreflected amounts of data will not lead to an improvement of the living conditions of EU citizens. - Introduction of substance-related mixing factors is nonsensical, since the behavior in mixtures does not represent a substance constant. Considering all conceivable mixtures fails due to sheer volume. - The claim that communication in supply chains is inefficient is unfounded. Criteria for this assessment are missing, and comprehensible measures are not mentioned. Potential outcomes from the unstated measures are not assessed. - The Commission overlooks the fact that the insurmountable complexity of dossiers is caused on the one hand by its own exaggerated specifications, and on the other hand by actual complexity in reality that defies regulatory simplification. The Commission must confront this complexity. - The increasingly generic regulatory approaches based on potential hazards of substances indicate insufficient coverage of the technical issues. It is unacceptable to undertake far-reaching regulation out of ignorance or on the basis of pure assumptions without detailed analysis of the real risk to be expected. - The enforcement of applicable laws varies among member states. It does not make sense to tighten or expand laws and regulations without first achieving uniform enforcement. If this is not possible, all further regulatory projects will be superfluous. The Commission should urgently shift its focus here from legislative to executive unification. - It is unrealistic and dangerous to the general welfare to assume without evidence that post-Covid reconstruction with simultaneous transformation to a "green" industry and sustainable society while maintaining living standards is achievable in the short term. - The fact that the Commission is willing to allow any number of jobs to be lost with the unfounded hope of improvement in an undated future is inconsistent with the EU Commission's mandate for public benefit and commitment to equal treatment. - The argument for extended regulation must not be that the financing and continued existence and even the expansion of an authority such as ECHA is secured by sufficient fees. This is a false self-image as a public servant and makes a mockery of previously accepted job losses for the general public.
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