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Downstream Users of Chemicals Co-ordination Group

DUCC

DUCC offers a platform for associations whose member companies use chemicals to formulate mixtures (as finished or intermediary products) for professional and industrial users, as well as for consumers.

Lobbying Activity

Response to Proposal for a basic regulation of the European Chemicals Agency

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.
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Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

2 Sept 2025 · Simplification chemicals

Meeting with Jessika Roswall (Commissioner) and

22 May 2025 · Chemicals policy and REACH revision

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné)

22 May 2025 · REACH, CLP

Response to Commission Roadmap to phase out animal testing

15 Oct 2024

The Downstream Users of Chemicals Co-ordination Group (DUCC) welcomes the opportunity to contribute to the Commission's roadmap and remains supportive of transitioning to animal-free chemical safety assessments.
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Response to Revision of the EU explosives precursors legislation

20 Aug 2024

Please find attached the feedback from the Downstream Users of Chemicals Co-ordination Group (DUCC).
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Response to Improving access to and availability, sharing and re-use of chemical data for the purpose of chemical safety assessments

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 Strategy for Sustainability (CSS) to improve the efficiency, effectiveness, coherence, and transparency of issuing safety assessments of chemicals across different pieces of EU legislation. Nevertheless, we share some considerations on the legislative proposal regarding the establishment of a Common Data Platform on Chemicals (CDPC). The proposal aims to ensure the efficient delivery of coherent hazard and risk assessments of chemicals where those assessments are required by EU legal acts, to achieve a high level of protection of human health and the environment, to enable the development and use of sustainable chemicals, to ensure the proper functioning of the single market for chemicals, and to improve the EU citizens trust in the scientific base for the decisions taken under EU legal acts on chemicals. DUCC welcomes the objectives of building a CDPC and driving a better chemical assessment coherence across EU legislations and considers that this will foster scientific progress and increase the availability of New Approach Methods data around chemical safety, as well as help in gaining and disseminating knowledge on chemical safety assessment. This new system might also contribute to reducing animal testing as the proposal concerns all sectors. In addition, collecting all available information in one place could make safety assessments more robust and faster, and consequently reinforcing citizens trust in the chemical safety evaluation and in decision-making process for chemicals. To ensure proportionality and reduce administrative burden mostly for SMEs, any potential duplication of information across various platforms should be avoided. Nevertheless, DUCC highlights some elements of the proposal in the attached document.
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Meeting with César Luena (Member of the European Parliament)

25 May 2023 · CLP

Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

DUCC represents 11 European associations, whose member companies use chemicals to formulate mixtures, ranging from cosmetics and detergents to aerosols, paints, inks, toners, pressroom chemicals, adhesives and sealants, construction chemicals, fragrances, lubricants, crop protection and chemical distributors industries. DUCC stresses the need to avoid double data requirements and to include within the Digital Product Passport discussions that have taken place in the past on "supply chain communication". We highlight our input in attachment.
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Meeting with Jutta Paulus (Member of the European Parliament) and European Federation of Essential Oils and Union of the European Lubricants Industry

3 May 2023 · CLP regulation

Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

17 Mar 2023

As a horizontal piece of legislation, CLP has a wide-ranging impact, with any change likely to have a knock-on effect on various sectors, including but not limited to biocides, pesticides, detergents, cosmetics, toys, and medical devices. For example, CLP Self-classification of substances is being included in horizontal regulations to trigger requirements without an assessment of impacts (e.g. urban waste water treatment directive, taxonomy). Revising CLP means changing the foundation of one of the most comprehensive pieces of legislation in the world and it is important to consider sectorial implications. Consumers and professional users buy paints, detergents, glues, inks etc., not chemicals. They purchase products made by DUCC members or articles containing products made by DUCC members. Since its creation in 2001 DUCC has acted with a united objective to contribute to the successful implementation of the REACH and CLP Regulations. DUCC raises the following points on the revised CLP text in our attached document.
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Response to European Year of Skills 2023

13 Dec 2022

DUCC is a platform of 11 European associations which represent downstream formulating industries from: cosmetics, detergents, aerosols, paints, inks, toners, pressroom chemicals, adhesives and sealants, construction chemicals, fragrances, lubricants, crop protection and chemical distributors industries. The group's main objective is to contribute, with a common voice, to the successful implementation of the requirements of chemicals legislation. We thank the Commission for the opportunity to comment on the EU Year of Skills. DUCC wishes to engage to make information on safe handling of chemicals more accessible and understandable for professional workers. In this context we think a valuable initiative could be to create an online platform at EU level that could provide information to professionals on: Generic safety training for different applications/professions (not substance-specific); Information on the applicable Occupational Safety and Health (OSH) requirements in each Member State: checklist for professionals; Information on the applicable REACH requirements: checklist for professionals; Information on safe handling to avoid impacts on human health and the environment; Additional training materials to support professionals with specific needs Access of information through this platform, would support in equipping the EU workforce with the skills needed so that the green and digital transitions are socially fair and just. Such a platform would be useful in different situations, such as: Supporting employers in giving the mandatory Occupational Safety and Health training for employees; Supporting self-employed professionals to achieve a similar level of protection as employed professionals; Serving as the proof of training for safe use of chemicals as defined in REACH; Providing a training source for those professionals with no/limited access to training otherwise; Providing skills on sustainable and durable solutions to professionals in support of the green transition. DUCC can also see how this initiative could aim for consistency with other EU policies in particular it represents an opportunity to target a long-standing issue: increased alignment between REACH legislation (under the EU Green Deal) and OSH legislation. Relevance to EU Year of Skills: As acknowledged in RECITAL 10 of the Proposal for a DECISION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on a European Year of Skills 2023, companies and other stakeholders know best what skills are needed in their industrial ecosystems, strengthening their collective action on skills development has to be part of the solution. The proposal in question is well in line with this objective. The platform also seeks to adopt learnings from other past projects. In the context of REACH and the diisocyanates restriction, industry along the entire supply chain worked closely together to develop the required sets of training materials and a platform for all users to access training for use of diisocyanates (https://www.safeusediisocyanates.eu/). Three DUCC members (FEICA, CEPE, EFCC) collaborated with other sectors across the supply chain on this project. These substances are crucial for important applications in the construction sector to enable repair and allow sustainability improvement (e.g. for adhesives, sealants, coatings and other applications of construction chemicals). DUCC and its members plan to engage on this topic and hope for such an initiative, contributing to the training and upskilling of the European workforce, to be supported as one of the building blocks of the European Year of Skills. We look forward to engagement and input on this issue.
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Response to Introducing new hazard classes–CLP revision

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 frameworks like, biocides, pesticides, detergents, cosmetics, toys, and medical devices. DUCC strongly urges the EU Commission to include sectorial implications in CLP impact assessments. Specifically in this case, impacts of the new hazard classes compounded with new expected requirements in REACH – i.e., the Generic Risk Management Approach. DUCC members are concerned with how implementation of these criteria at European, rather than UN GHS level will impact global competitiveness of EU companies and the hazard communication for export of EU-manufactured chemicals. A lot of research is still ongoing for some of these hazards. Considering that the science is still not fully mature, DUCC members fear the effects of first a precipitous implementation of criteria in the CLP, and second, to then have to change the classifications in a few years based on a better-informed decision at the UN GHS level. To at least ensure the best possible implementation of the criteria at EU level, we urge Commission to consider the following points: ENDOCRINE DISRUPTOR DEFINITION Potential changes to the CLP regulation must consider consistency with international regulatory instruments and definitions. The foreseen CLP ED criteria should be similar, if not identical to those laid out for plant protection and biocide products, based on the WHO criteria. We find the definition of “biologically plausible link” for EDs could be improved due to: i. the lack of indication of precise test methods linkable to OECD methodologies ii. how such links could be interpreted considering the aims to increase New Approach Methodologies iii. the loosely defined criteria for weight of evidence (which permits use of peer-reviewed studies that lack the level of control of GLP studies) iv. Clarifying what is meant for “conclusively”, the word is repeated in the text DATA TO CLASSIFY SUBSTANCES AS “MOBILE” UNDER CLP To decide whether a substance is Mobile or Very Mobile DUCC members deem useful: i. That additional data must be allowed using a “weight of evidence approach” ii. The proposed Koc (organic carbon/water partition coefficient) end-point is not considered an applicable metric to simulate Mobility for ionisables. Ionisable substances consitute a significant portion of all REACH dossiers iii. To further describe the concept of ‘relevant’ (Ref: relevant conditions, relevant constituents or impurities of a substance and relevant transformation and/or degradation products - Page 14 – section 4.3.2.3, Page 19 – section 4.4.2.3) TRANSITION TIMELINES For substances already placed on the market before the regulation entry into force, the transition time for labelling is longer than that allowed for mixtures i.e., 42 months and 36 months respectively. The experience of DUCC members is that most labelling to align substances to the new hazard classes will occur towards the end of the transition period. This could lead to a mismatch with the deadline for mixtures. DUCC members would then have to carry out multiple updates within a short timeframe as information on substances will be shared up to 6 months after the deadline for mixtures. If all substances were labelled before the transition period for mixtures ends, this allows further clarity along the supply chain. PROTECT THE EU SINGLE MARKET The different criteria and Endocrine Disruptors lists between the EU regulations (i.e. REACH, CLP, Cosmetic) and also via member state actions like the French AGEC law have led to confusion for industry, in particular regarding member state specific requirements. We ask Commission to act to protect the single market.
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Response to Improving access to and availability, sharing and re-use of chemical data for the purpose of chemical safety assessments

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 administrative obstacles’. • DUCC members are largely downstream user of chemicals and thus are often recipients of data from suppliers. However, may also generate data for REACH Registration, but also other regulatory purposes (pesticide regulation, biocidal product regulation, biodegradability for detergents, food contact etc.). Data generation is also expected under the new requirements for Polymer Registration topic and will be a topic of increasing importance with the new requirements of the Green Deal. • DUCC agrees that good access to data by regulatory agencies is important • It is crucial that this is made possible respecting data protection (data access rights) and confidential business information (e.g. confidential technological processes, persons names) • The weight of evidence criteria must be clear and reliable • Data collected should be limited to relevant chemical substances only (data access to chemicals that are placed on the market only). • Data generated by companies for R&D purposes should remain confidential, this is vital to encourage innovation.
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Response to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)

20 Sept 2021

The Downstream Users of Chemicals Co-ordination group (DUCC) welcomes any initiative that aims at improving protection, while fostering investment that can be justified from an economic, social, and environmental perspective for a digital transition. DUCC members are keen to engage with stakeholders on priority information to leave on packaging and supplementary information to be made available online. However, actions to be taken to simplify and digitalise labels should not only be targeted at the European industry but also at society through education as it may require changes in consumers’ habits and practices. We would like to note that there is a significant overlap between various legislative requirements for labelling on packaging resulting from existing chemicals legislation. Therefore, we call on the European Commission (EC) to build on its Better Regulation Agenda and address duplication of information and inconsistencies as a result of different regulatory requirements. A summary of DUCC’s comments is presented below (cf. Attachment): -DUCC would like to stress the importance of promoting EU activities to simplify and digitalise labels at UN level as global alignment is very important for a proper functioning of the internal market as well as global trade. DUCC calls on the EC to constructively participate at UN level. -DUCC calls for “end-user relevant” labels that consider the end-user’s (e.g., consumers, professional users) needs and provide correct information to ensure the safe and efficient use of the end-product. -DUCC favours digitalisation but sees an urgent need for simplifying labels to make them less confusing and more understandable, e.g., approved icons for phrases could help with simplification and improve public understanding. -DUCC in general supports simplification by removing certain labelling requirements for consumer products and is of the opinion that potential de-materialization of product information could also improve the layout and readability of on-packaging labels. Digitalisation should support sustainability objectives by reducing packaging and packaging waste. -DUCC would like to reiterate that digitalisation should not be a pretext to require information digitally on top of information that is already provided on the packaging. -DUCC would also like to point out that it is very important to assess the impact of possible changes for the many thousands of DUs (many of them being SMEs) operating in the EU. -In DUCC’s view, digitalisation should not be forced in cases where costs exceed benefits and a possibility should be left for a voluntary digital approach, in addition to a physical label. -In DUCC’s view, requirements linked to the digital transition should be ‘technology-neutral’ as such technologies evolve rapidly. -A legal option should be left open to provide all information on-packaging or alternatively to provide only essential information on-packaging, useful at the moment of purchase, and provide remaining information digitally that is useful before use but after purchase. This is of key importance especially for labelling of small packages (< 125 ml). -DUCC would like to note that simplification can also be achieved with multilingual-fold-out labels. Regulation (EC) No 1272/2008 should clarify how multilingual fold-out labels can be used within the EU more easily. -DUCC is well aware that the Biocidal Products Regulation is currently not included in the scope of the Inception Impact assessment, however we would suggest the EC to consider including this Regulation in the scope of the roadmap.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

31 May 2021

DUCC urges the European Commission not to rush decision-making processes for CLP (or any other legislation) in order to meet unrealistic deadlines, set in the CSS, but to ensure that these are conducted properly in line with the principles of Better Regulation. Realistic transition periods to implement any changes to CLP should be introduced and, as DUs rely to an extent on information from upstream suppliers, consideration should be given to sequential application deadlines and/or grace periods to sell stocks. That would ensure sustainable clearance of available stocks without unnecessary waste and/or product re-work and unnecessary transport of goods. DUCC also considers that potential changes of the CLP regulation should consider consistency with international regulatory instruments and definitions. It is very important to assess the impacts of proposed changes to the hundreds of DUs (a lot of them being SMEs) operating in EU, as, taking into account the additional hazard identification, notification and the possible associated re-labelling, the monetary and administrative burden for DUs could be significant. The CSS will create new links between CLP and downstream legislations. Such links should recognise the limitations of hazard identification and be relevant and proportionate for downstream sectors. Safeguards, such as exemption procedures, must be introduced both under REACH and sector-specific legislation to avoid unjustified bans of uses that are safe for consumers and the environment. Disproportionate action should be avoided for substances that are merely “suspected” of hazard properties. Regulatory links should be legally clear, also to avoid negative impact on SME’s being not aware of all regulatory changes. It is important that all sectors have equal and fair access to scientifically valid and regulatory-accepted tools for innovation that fully respect provisions and restrictions on the use of animal tests. The synopsis of DUCC comments is presented below (see full comments in attachment): Introduction of new hazard classes (such as endocrine disruptors) and corresponding criteria: The inclusion of new hazard classes should first be done under the UN GHS framework. It is important that the new hazard classes are based on internationally accepted definitions and do not lead to an increase of animal testing. EU COM is to establish and promote acceptance of alternative methods. DUCC disagrees with the approach taken by the COM to consider CLP as the only option to identify EDs without evaluating other potential options under the REACH regulation. REACH has already demonstrated its ability to identify and assess EDs. The implementation of ED identification criteria under REACH could be done in the same way as PBTs via an Annex. Clarification of the obligations to classify mixtures and some complex substances: It is essential that chemical substances are classified and labelled using relevant, reliable, and robust scientific data, prior to this information being communicated down the supply chain. Any additional obligations should not diminish abilities of DUs to independently confirm what endpoint data should be made available by a supplier and to make the correlation between substance classification and any supporting data reported by a supplier. Multilingual fold-out labels and introduction of tailored labelling rules where there is not enough space on packaging: DUCC welcomes the initiatives and is of the opinion that such labels will be beneficial to safety by offering the possibility to improve layout and readability and greater number of consumers/users will be able to receive information in their native language. Digitalisation. Digital tools could enable constant access to up-to-date information on safe and sustainable product use. Broad use of digital tools will add to sustainability as it will reduce the need to change or withdraw goods already in the supply chain.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

DUCC members are highly committed to successfully implement REACH which has been one of the most important regulations to ensure consumers and products safety in Europe on chemical risks. However, DUCC is of the opinion that any future actions to be taken should preferably involve using and strengthening existing tools as the set goals could be achieved by securing an overall better implementation of REACH regulation and harmonisation of requirements between all horizontal legislations related to chemicals management. In order to decrease burden to authorities and speed up the REACH processes industry could actively participate in developing RMO analysis/ identifying chemicals of concern with MS authorities/ ECHA. The full supply chains should be involved in an effort. It could be noted that Industry has the resources and expertise to provide help in defining various concepts and finding appropriate solutions. At last, actions to be taken should not only be targeted at EU industry but also involve society as whole (better education) as might require to make changes to individual behaviour in day to day life. Full DUCC comments are attached as separate document to this consultation. The synopsis of DUCC comments is presented below: Generic approach to risk management: Regulating chemicals only on the basis of their hazard, is excessively simplistic and risks discriminating and removing from the market chemicals with high societal, environmental and economic benefits. The ‘generic risk management’ approach (based on hazard) should be applied in a targeted way, to substances and/or uses where adequate control of risk has not been demonstrated. Essential Uses: DUCC recognises that discussions on this topic and any potential decisions on what will be recognised as an “essential use” will be of highly political nature with unavoidable socio-economic consequences. In our view a generic “definition based” approach to “essentiality” is not a solution that can ensure sufficient clarity and predictability to industry and consumers. Combination effects of chemicals and mixture assessment factor (MAF): DUCC is not in favour of introduction of one generic/ fixed MAF to be applied to all chemicals. A blanket MAF would be arbitrary and not based on science, covering largely hypothetical exposures and risks rather than real-life scenarios. In our view, the default application of an additional safety factor such as MAF would result in unrealistically high use of the precautionary principle. Simplifying communication in the supply chains: Communication on how chemicals can be used in a safe manner along the supply chain is key to secure proper risk control by downstream users. Thus, DUCC acknowledges the key role of formulators in the centre of the supply chain and reiterates its commitment to the improvement of supply chain communication and welcomes EU COM initiative to look for ways how to improve communication in the supply chain. One substance one assessment: The concept could be appropriate if it is only applied to the hazard assessment as it could streamline the process and seemingly different outcomes due to hazard assessments carried out at different times by different bodies, under different legislations could be avoided. Polymer registration: Only polymers of concern should be subject to registration. The data requirements, tonnage cut-offs, testing schemes should account for polymer specificities and should be understandable, implementable, and transparent. Enforcement: Better cooperation between Enforcement authorities in different MS is needed in order to establish harmonised interpretations and enforcement practices across EU. The evaluation of registration dossiers is complex: DUCC would like to reiterate that DUs could contribute to this process, as they may be in possession of information useful for substance evaluation, such as use and risk assessment data, sometimes measured data.
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Response to Chemicals strategy for sustainability

19 Jun 2020

The Downstream Users of Chemicals Co-ordination group (DUCC) welcomes the opportunity to provide input to the European Commission Roadmap on the Chemicals Strategy for Sustainability. Please find hereby attached our contribution to this consultation.
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Response to Amending requirements for information for poison centers

9 Jun 2020

DUCC – representing eleven European associations whose member companies use chemicals to formulate mixtures for professional and industrial users, as well as for consumers - welcomes the second amendment to CLP Annex VIII incorporating vital workability solutions, but expresses its concerns about the timeline for implementation of this amendment. These concerns are reflected and elaborated in the attached letter, which was co-signed by ten of DUCC’s member associations along with other sector organisations. DUCC expresses its support for the Interchangeable Component Group (Part B, 3.5) as a general solution making the notification requirements workable for many sectors, and for the further modifications to the draft legal text which were agreed in the web meeting of CARACAL on 15 May 2020. DUCC remains concerned however about the proposed arbitrary limitation to five components in the case of an ICG classified for skin corrosion, skin irritation, eye damage, eye irritation, aspiration toxicity, or respiratory or skin sensitisation (or a combination thereof). No substantive rationale, scientific or otherwise, has been presented for such limitation to the number of interchangeable components, and members have confirmed that a product formulation can have more than five components that are used interchangeably. In the opinion of DUCC it is not justifiable to impose such an applicability limit without a sound and clearly communicated basis.
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Response to Amendment of REACH Annex II (Safety Data Sheets)

10 Oct 2019

DUCC thanks the European Commission for the opportunity to comment, via public consultation under the Better Regulation agenda, on the proposed draft Commission Regulation amending Annex II to Regulation (EC) No 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Safety data sheets (SDS) are a very important tool for communication in the supply chain, and DUCC welcomes the efforts of the Commission to update this Annex and to align it with the 6th and 7th revised editions of the Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the provisions of Annex VIII to Regulation (EC) No 1272/2008 (CLP) and the new provisions for nanoforms of substances according to Commission Regulation (EU) 2018/1881. Nonetheless DUCC would like to provide a number of comments and suggestions on both the draft regulation and its annex: see attached document.
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Response to Amending Regulation (EC) No 1272/2008 relating to emergency health response

29 Jul 2019

DUCC represents mixture-formulating industries in Europe, which are almost universally impacted by the requirements of CLP Annex VIII. DUCC welcomes the postponement of the application deadline for consumer products to 1st January 2021. This serves as a positive example of the European Commission responding to the needs of Member State Competent Authorities and industry, and DUCC commends the Commission for this decision. DUCC also welcomes many of the other changes and clarifications in this draft, including the requirement for reporting of pH which is now aligned more closely with the UN GHS; harmonisation with international standards is an important and value-added practice. Nonetheless DUCC would like to express some remaining concerns about the proposed changes, as elaborated in the attached document.
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Response to Revision of the Regulation on marketing and use of explosives precursors

27 Jun 2017

DUCC, a joint platform of 11 European associations whose member companies use chemicals to formulate mixtures (as finished or intermediary products) for professional and industrial users as well as for consumers, welcomes the opportunity to give input on the proposed revision of Regulation (EU) 98/2013 on the marketing and use of explosives precursors. DUCC fully supports any effort aimed at improving communication in the supply chain regarding the reporting requirement for suspicious transactions. In this context DUCC wishes to submit the attached comments regarding possible improvements to the identification of products covered by these reporting requirements.
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and European Chemical Industry Council and

21 Mar 2017 · Reach evaluation

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

14 Jul 2015 · Industrial initiatives in the field of energy efficiency. Case: Zeeland.