FIPEC
La Fipec représente cinq associations professionnelles nationales et agit pour défendre les intérêts sectoriels qu'elle représente et pour promouvoir ses secteurs d'activités.
ID: 139961447855-03
Lobbying Activity
Response to Revision of the Toy Safety Directive
31 Oct 2023
The paints, varnishes, coatings, adhesives and sealants, printing inks and artists' colours industries that Fipec represents in France are paying particular attention to the proposal for a regulation on the safety of toys, both as toy manufacturers (mainly in the artists' colours industry) and as operators (downstream users) upstream of the toy industry, in terms of paints and varnishes as well as adhesives and printing inks. Our concerns about the proposal of the new regulation on the safety of toys are multi-layered and lead us to make the considerations gathered into the attached file.
Read full responseResponse to Environmental claims based on environmental footprint methods
20 Jul 2023
Madame, Monsieur, Vous trouverez ci-jointe la contribution de la FIPEC à la consultation publique portant sur le projet de directive relative à la justification et à la communication des allégations environnementales explicites. Sincères salutations,
Read full responseResponse to Revision of EU legislation on hazard classification, labelling and packaging of chemicals
30 Mar 2023
With regard to the revision to the CLP Regulation, and the documents published on the 19th December 2022, FIPEC would like to share the following comments on four important topics: Regarding transition periods and definition of placing on the market (OLP text and Delegated Act), once again, we call to take into account the need for sufficient time for mixture manufacturers to act with respect to relabelling and reformulate due to substance reclassifications. We therefore suggest allocating adequate transition periods in the regulatory texts, so that downstream users can reclassify and relabel their mixtures under conditions adapted to the capacity of our industry to act. We recommend setting a minimum of 24 months transition period for all transition periods that relate to mixtures. To this end, it could be considered the transition period for updating labels (article 30(1)) to be established on the same principle as the proposal of amendment of Article 61 of the CLP Regulation: a first transition period for products placed on the market for the first time, followed by a consecutive transition period for products that have been placed on the market before the end of the first transition period. We would also strongly encourage the authorities to consider aligning the CLP legislation with other regulatory frameworks with regards to the definition of placing on the market with first placing on the market. Regarding digital labelling, the digitalisation possibilities set out in Article 34b of the proposal of text fall far short of our expectations regarding the introduction of digital label formats in the CLP Regulation. We call on the authorities to take a more ambitious approach to digital labelling and reiterate our call for more pragmatism and flexibility in this measure. This leads us to formulate the following proposal for a first stage of prioritization of the information mentioned on the physical labels. The objective that seems us essential is the appropriate providing of information to the purchaser of the product (at the time of purchase) as well as to the user of the product (at the time of handling the product). We suggest that, at least, these statements which are currently exempted for products and sales units not exceeding 125 ml should become statements that could be digitalised for products with a capacity of more than 125 ml by the legislative act revising the CLP Regulation. Regarding fold out labels, we welcome the possibility of using fold-out labels where necessary. However, the use of fold-out labels should remain only as an option to allow their use in specific cases, notably when the product is marketed in several countries with different languages. Using fold-out labels should remain limited to these specific cases and not become the only solution to meet the regulatory labelling requirements for a single-language label. Regarding the minimum labelling requirements, we are aware that labels for mixtures are increasingly difficult to read due to additional information requirements (often due to re-classifications of substances). However, the measures in the proposal of text regarding the minimum font sizes and new requirements regarding line spacing and label background do not seem to us to be the answer to this challenge. On the contrary, we believe that the option of transferring some mandatory information to a digital format is the best way to solve this problem. This could be combined with a measured evolution of the minimum requirements for physical labelling with a sufficient transition period for implementing them.
Read full response