OpenLobby.EU
Explore

International Chemical Secretariat

ChemSec

The International Chemical Secretariat is a non-profit organization advocating for a toxic-free environment.

Lobbying Activity

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

11 Dec 2025 · Future of REACH revision

ChemSec calls for toxic-free material cycles in EU circularity

6 Nov 2025
Topic — This consultation explores legislative measures to enhance EU economic security through circular production.
Message — ChemSec advocates for phasing out the most harmful substances from all products to ensure safe recycling. They request strengthened REACH regulations to regulate chemical groups and provide full traceability of contents. They also insist that recycled materials must meet the same safety standards as virgin materials.123
Why — These measures would benefit businesses by rewarding innovation in safer chemicals and securing public trust.45
Impact — Companies seeking lower standards for recycled goods would lose the ability to market contaminated materials.67
Read full response

Meeting with Jessika Roswall (Commissioner) and

15 Oct 2025 · To discuss REACH revision

Meeting with Veronica Manfredi (Director Environment)

15 Oct 2025 · PFAS

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

14 Oct 2025 · Follow-up discussion of chemicals legislation (omnibus + REACH)

Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

2 Sept 2025 · Upocming legislations pertaining to chemicals (Chemical omnibus and REACH revision)

ChemSec warns EU Taxonomy changes undermine chemical safety rules

26 Mar 2025
Topic — This consultation seeks to simplify sustainability reporting by making certain Taxonomy requirements more flexible.
Message — ChemSec strongly opposes weakening safety criteria for hazardous substances and urges the Commission to maintain existing standards. They also reject proposals to limit the scope of reporting to only the largest firms.123
Why — Maintaining current standards prevents unsustainable investments and avoids the high costs of future hazardous chemical substitutions.45
Impact — Investors and public health are harmed by reduced data transparency and increased exposure to toxic chemicals.67
Read full response

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

26 Mar 2025 · Chemicals policy: REACH revision and PFAS

Meeting with Paul Speight (Head of Unit Environment) and European Environmental Bureau and

14 Feb 2025 · EU chemicals regulations / REACH revision

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall), Vita Jukne (Cabinet of Commissioner Jessika Roswall)

29 Jan 2025 · ChemSec made a short presentation including their investors and company work. Mr Ceyssens offered a short description on the priorities for Commissioner Roswall.

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

ChemSec acknowledges the need to gather input to the guidance for Social Climate Funds. When applying the concept of Do No Significant Harm (DNSH), it is crucial to properly define what that entails. In the version from 4thJune 2021 of the EU taxonomy climate delegated act the DNSH criteria for pollution prevention & control already mentioned the essential use concept. It was revised due to the fact that the essential use concept had not been established. In April 2024, the EU Commission set out the principles for essential use, therefore it should be reintroduced to better protect societies and environment from pollution. The guidance for the Social Climate Fund should therefore follow the original proposal regarding chemicals, including reference to essential use. The substances listed in section a) to f) are legally addressed by the placing on the candidate list and are sometimes restricted or requiring authorisation by other legislation. For the section g) some substances are regulated but there are no general requirements in place. Nevertheless, all these substances do have intrinsic properties and impacts to health and environment, and every company should have knowledge of their use of these substances. For process chemicals and chemicals needed for the functioning of our society the essential use concept should offer the possibility to use hazardous substances if no alternative is available and the use is essential. Additional to the original categories we suggest including: h) persistent substances as defined in (1) Regulation on persistent organic pollutants and in (5) REACH (transferred to CLP)) The knowledge about the PFAS pollution is rising more and more, the remediation costs for one year of PFAS production are exceeding the global GDP. Insurers are excluding the substance group from issuing new insurances and societies are left with enormous health and environmental costs. To avoid further increase of the PFAS crisis, this substance group should not receive any EU funds.
Read full response

ChemSec Urges Civil Society Inclusion in Chemical Data Platform Governance

4 Apr 2024
Topic — This consultation concerns a regulation creating a common data platform for chemical assessments.
Message — ChemSec calls for chemical data to be readily available to all relevant actors. They recommend including civil society organisations in the steering and governance of the platform. The group also welcomes the proposal to introduce an independent data generation mechanism.123
Why — Wider access to data helps the group investigate obscure parts of the chemical market.4
Impact — Certain companies lose the benefit of keeping chemical safety data hidden from public view.5
Read full response

ChemSec urges EU to ban all bisphenols in food packaging

7 Mar 2024
Topic — Proposed EU restrictions on bisphenol A and similar chemicals in food contact materials.
Message — The restriction should cover all bisphenols in all food contact materials to prevent unsafe substitutions. The mechanism must also include suspected hazardous substances and those self-classified by manufacturers. The Commission should ban non-threshold substances instead of just limiting their migration into food.123
Why — This would advance their mission to achieve a environment free of hazardous chemicals.4
Impact — Chemical manufacturers and the recycling industry would face stricter bans and higher costs.5
Read full response

Response to 8th Environment Action Programme – Mid-term Review

26 Jan 2024

ChemSec strongly supports the 8th Environmental Action Programmes long-term vision for 2050 as well as priority objectives for 2030. We find it extremely important to ensure that the enabling conditions are used to their full potential and that all relevant EU legislation contribute to the overall goals of the EAP. As an NGO working mainly with EU chemicals policy, we find two of the thematic objectives particular important. These are the objective of "pursuing zero pollution, including in relation to harmful chemicals in order to achieve a toxic free environment including for air, water and soil" as well as the objective to "reduce key environment and climate pressures related to the Unions production and consumption." It is clear to us that the interlinked objectives of the Action Plan cannot be attained without the full use of the enabling condition described in point (l): "swiftly substituting substances of concern including SHVCs, EDCs, very persistent chemicals, neurotoxicants and immune-toxicants as well as tackling the combination effects of chemicals.." We find it very important that the Commissions midterm report focus particularly on this issue, since this is an area that suffers from detrimental lack of progress. The Commissions Chemicals Strategy for Sustainability (CSS) clearly acknowledged that exposure to harmful chemicals is ..a threat to human health. In addition, chemical pollution is one of the key drivers putting the Earth at risk, impacting and amplifying planetary crises such as climate change, degradation of ecosystems and loss of biodiversity . In line with this conclusion, the chemicals strategy committed to substitute the most harmful substances via restrictions a under the REACH Regulation as well as several other legislative acts. The strategy also committed to revise the REACH Regulation in order to ensure better protection of human health and the environment in the future. However, despite the fact that the strategy was warmly welcomed by both the Council and Parliament as well as by a large number of stakeholders there has been almost no progress in this work. There are still multiple harmful substances on the market which affect the environment, including biodiversity and human health, and this problem will not be solved without clear legislation to control and phase out the chemicals that cause harm. Based on these considerations, we encourage the Commission to clearly address the issue of problematic chemicals in the midterm report for the EAP. The report should shed light on the plans to fulfil the commitments of the CSS as well as the plans for its follow up as part of the long-term perspective towards 2050. In doing so, the most harmful substances as defined in the CSS should be given highest priority. Finally, we support the development of a framework of indicators to monitor the drivers and impacts of chemical pollution and to measure the effectiveness of chemicals legislation in line with the CSS. Important indicators in this respect would be: a) Progress in legislation b) Developments in the volume of Substances of concern on the market c) The completeness of the hazard information for chemicals on the market d) Number of sites suffering from chemicals contamination, such as PFAS.
Read full response

Response to Revision of the definition of engineered nanomaterial in food

10 Jan 2024

Chemsec welcomes the opportunity to provide feedback on the draft Delegated Act updating the definition of engineered nanomaterial in the Novel Food Regulation (EU) 2015/2283. However, we are concerned that if the nano labelling would disappear from substances which contain fewer than 50% of particles smaller than 100 nm this would constitute a setback in food safety, consumer protection and the right to know. We urge the Commission to consider that: - The draft delegated act is very similar to one that was rejected by the European Parliament in March 2014 as it was considered that a threshold of 50 % would not be in the line with the aim of consumer protection. - The proposed definition of the term manufactured nanomaterial would be challenging to implement from a regulatory standpoint. - A large number of substances would get out of authorities' oversight and consumers would be left in the dark if the nano labelling obligation would disappear from substances which contain fewer than 50% of particles smaller than 100 nm. The threshold could instead be set at 10 % in line with recommendation from the French Authorities (Anses, April 2023)
Read full response

Response to Revision of the Toy Safety Directive

30 Oct 2023

Overall, we welcome the focus on increased protection from the most harmful substances for children from the use of toys, and the strengthening enforcement of this product group. We also support transforming the directive into a regulation. We particularly welcome the following elements of the proposal: The addition of Endocrine disruptors for human health cat. 1&2, STOT SE/RE cat. 1 and respiratory sensitisers to the list of generally prohibited substances in toys. Limit values that previously only applied to toys for children under 3 now apply to all toys. Introduction of a "Product passport" where information about "Substance of Concern" must be available. We think the following is missing from the proposal: Chemicals that have a major environmental impact such as PBT, vPvB, PMT, vPvM and EDCs for the environment is not included in the generic ban in the proposal. To be in line with the Chemicals Strategy, which is aimed at phasing out all of the most harmful substances from consumer products, these environmental hazards need to be included as well. PFAS should, in line with the Chemical Strategy, also be banned in Toys. Upcoming classifications such as immunotoxic and neurotoxic should be included in the regulation as soon as they become official classifications. Skin sensitizers should be included in the group of generic banned substances since many toys have been shown to contain these types of chemicals. Ban on the entire group of bisphenols. While we welcome the ban on BPA we question why the ban is not for all bisphenols. Banning only BPA risks leading the industry to switch to other, equally problematic, bisphenols, which makes the ban on BPA toothless. The proposed limits for nitrosamines and nitrosable substances should apply to all types of toys, not just for toys aimed at children under 3 years. Information regarding the most harmful chemicals. When a product has been granted a derogation and contains one of the generally prohibited substances, this must be clearly indicated on the product so that consumers and recyclers are fully informed about the content of these substances in the product. Defined limit values. Its proposed that prohibited substances should be acceptable at trace levels but only if their presence at such level is technologically unavoidable with good manufacturing practices. Overall, we support this but we are concerned this is unclear and might open up for different implementations and might create unnecessary confusion in the industry. We therefore propose clear limit values for all prohibited substances. We think the following needs to be clarified: When derogations can be granted. We do not support derogations due to safe use and when no alternatives are available since the aim of this regulation is to improve the protection of children from the most harmful chemicals and giving derogations from this would undermine this aim. To be in line with the Precautionary principle as well as the Chemical Strategy derogations to use the most harmful substances in children's toys grounds should not be given. If derogations are needed these should be very limited, well justified, well-defined and time limited. It also needs to be clear how and by whom this evaluation should be done. Product passports must contain all "Substances of Concern" (SoC), including those substances that are self-classified and meet the requirements for SoC. We welcome that combination effects should be taken into account. However, how this shall be taken into account needs to be clarified since it is very unclear from the proposed writing. We support a protective and appropriate mixture assessment factor (MAF) to be included in the regulation.
Read full response

Meeting with Martin Hojsík (Member of the European Parliament)

19 Sept 2023 · PFAS

ChemSec demands mandatory disclosure of hazardous chemical use

7 Jul 2023
Topic — The Commission is defining specific standards for corporate sustainability and environmental reporting disclosures.
Message — The Secretariat opposes voluntary reporting to ensure data remains reliable and uniform. They support disclosing hazardous substances so investors can assess chemical risks.12
Why — Mandatory reporting would expose chemical risks, advancing the group's toxic-free environment goals.3
Impact — Companies would lose flexibility and face higher costs from complex chemical reporting requirements.4
Read full response

ChemSec demands toxic-free standards for green product claims

7 Jul 2023
Topic — The EU is consulting on rules to prevent greenwashing through standardized footprint methods.
Message — ChemSec demands that green claims reflect actual material content rather than creative bookkeeping. They argue products must be free from hazardous substances to be marketed as green.12
Why — Truly non-toxic and sustainably produced materials would gain a clear market advantage.34
Impact — Firms using accounting tricks or harmful chemicals would be barred from using green labels.5
Read full response

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

1 Jun 2023 · Taxonomy delegated act

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

1 Jun 2023 · Taxonomy delegated act

ChemSec warns against creative accounting for recycled plastic bottles

30 May 2023
Topic — The EU is setting rules to calculate and report recycled content in plastic bottles.
Message — ChemSec demands removing references to chemical recycling and creative mass balance accounting. They urge for reporting that reflects true content through strict, batch-level traceability.12
Why — This ensures truthful consumer information and protects mechanical recyclers from unfair competition.34
Impact — Large chemical companies lose the ability to use credit transfers for marketing products.567
Read full response

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Nordea Bank Abp and

24 May 2023 · REACH revision

ChemSec Urges Inclusion of Chemical Manufacturing in EU Taxonomy

26 Apr 2023
Topic — The Commission is defining sustainable economic activities to guide green investments in Europe.
Message — ChemSec urges the inclusion of chemical manufacturing to drive industry sustainability. They request keeping strict criteria for substances of very high concern.12
Why — Clearer rules would help investors assess risks and avoid financial volatility.34
Impact — Chemical companies producing hazardous substances would be excluded from green investment funding.5
Read full response

ChemSec calls for faster classification of hazardous chemical groups

30 Mar 2023
Topic — The EU is revising legislation on classifying, labelling, and packaging hazardous chemical substances.
Message — ChemSec urges authorities to fast-track classifications and adopt a grouping approach for hazardous substances. They request new hazard classes for neurotoxicity and immunotoxicity to increase consumer protection. Clear hazard labels must remain mandatory on physical product packaging.1234
Why — This would accelerate the phase-out of toxic chemicals, advancing the organization's mission.56
Impact — Chemical manufacturers face broader market restrictions and higher costs through substance grouping.78
Read full response

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

27 Feb 2023 · Implementation of the EU Chemicals Strategy for Sustainability, in particular investors’ interest in more health- and environment-friendly chemicals.

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius)

27 Feb 2023 · Implementation of the EU Chemicals Strategy for Sustainability, in particular investors’ interest in more health- and environment-friendly chemicals.

ChemSec calls for PFAS removal in wastewater directive

2 Feb 2023
Topic — The consultation addresses updated environmental and health standards for treating urban wastewater discharges.
Message — ChemSec requests the inclusion of PFAS removal in advanced wastewater treatment mandates. They emphasize addressing contamination immediately as product restrictions are years away.12
Why — This proposal directly supports the organization's core mission for a toxic-free environment.3
Impact — Chemical producers and water utilities would face significant costs for advanced filtration.4
Read full response

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

ChemSec welcomes the opportunity to give input to the Commission on the Fitness Check of the important Polluter Pays Principle. The use of harmful chemicals may induce adverse health effects such as cancers, autoimmune disorders and infertility and negatively impact the environment. Scientists have, for example, linked the fact that men in the Western world produce half as much sperm as they did 40 years ago to exposure to toxic chemicals. Other studies link exposure to toxic chemicals to a loss of four to five IQ points in children. Many studies have also shown how large the costs to society are due to the widespread use of harmful chemicals. The polluter pays principle (PPP) is an important cornerstone in EU regulation. A chemicals policy aiming to eliminate hazardous substances needs to use the Polluter pays principle as an incentive to develop and use the least hazardous substances available. Companies that produce and use hazardous chemicals are today mostly not affected economically by costs or less revenue from the pollution their products cause. Moreover, producers and users of the most harmful chemicals are not given economic incentives to substitute and phase out the problematic chemicals in favour of safer alternatives. To apply the PPP effectively to chemicals we propose to focus on the production, import and use of substances of concern (as defined in the Chemical Strategy for Sustainability). The PPP should apply to the specific chemical as well as when its included in mixtures, articles and in products to be efficient and relevant. If the PPP would be applied only when a clear connection can be found between a certain substance and a certain measurable effect in humans or in the environment the outcome would be very limited. Chemicals are widely spread throughout the environment, society and our bodies and are used in many products and processes. Therefore an effective approach is to focus on the production, use and import of the most harmful substances. Attached you find a number of important studies we suggest the Commission to take into account in this work.
Read full response

ChemSec demands stricter rules and faster labeling for hazardous chemicals

18 Oct 2022
Topic — This consultation concerns revising chemical regulations to identify and label new hazard classes.
Message — ChemSec calls for more stringent criteria and significantly shorter transition periods for labeling hazardous substances. They argue the current five-year delay for mixtures hides vital safety information from consumers.123
Why — This accelerates the identification of hazardous substances to achieve a toxic-free environment.4
Impact — Chemical producers would have less time to comply with more stringent classification requirements.5
Read full response

Meeting with Virginijus Sinkevičius (Commissioner) and

8 Sept 2022 · To exchange views, upon ChemSec’s request, on the implementation of the Chemicals Strategy and in particular on the ongoing work by the Commission for the revision of REACH

Response to Safety requirements to be met by European standards for certain children products (excluding toys)

2 Sept 2022

ChemSec welcomes the Commission’s draft decision on safety requirements to be met by EU standards for certain children’s products. Our comment concerns mainly the topic of chemical hazards. It is difficult to predict the behavior of children or the fate of the product in the waste-stage. Therefore, it is hard to define safe use. Consequently, it is necessary to adhere to the precautionary principle and avoid the use of substances of concern. This must go beyond what is stated in the annex: “Standards shall reflect latest chemical guidelines and relate specifically to knowledge regarding the safety and health of children (regarding mouthing, inhalation, and absorption).” It is good that the annex mentions that safety-by-design is to be prioritized. This should be linked to the properties of chemicals that are being used in the product (similarly to the definition of safe-and-sustainable-by-design chemicals that is currently underway).
Read full response

ChemSec urges stricter confidentiality rules for chemical data transparency

16 Aug 2022
Topic — EU initiative to improve chemical data accessibility and reuse for safety assessments.
Message — ChemSec calls for a review of confidentiality policies to make claims harder to justify. They suggest centralizing data handling at ECHA to improve access for authorities and NGOs. This would ensure assessments use the same data for consistent outcomes.123
Why — Increased transparency would accelerate efforts to replace the most hazardous substances in products.4
Impact — Organizations that use confidentiality claims to hide data will find it harder to operate.5
Read full response

Meeting with Elena Montani (Cabinet of Commissioner Virginijus Sinkevičius) and ClientEarth AISBL and

8 Jul 2022 · Implementation of the EU Chemicals Strategy for Sustainability and REACH revision

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and

8 Jul 2022 · Implementation of the EU Chemicals Strategy for Sustainability and REACH revision

Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

ChemSec appreciates the opportunity to give feedback to the call for evidence supporting the review of the RoHS directive. To improve the RoHS directive, ChemSec believes that it is preferable to propose ‘hard’ legislative measures rather than ‘soft’ non-legislative measures and that the desired outcome will not be reached by incorporating the directive in the REACH regulation or in the ecodesign directive. The RoHS directive has a clear purpose that has been served well over the years. When it was implemented in 2003 it changed the electronics industry for the better: made available more alternatives and removed numerous hazardous substances from electronics. The scope of the legislation, that all products are included, has been a success factor. It is imperative that the scope is not in any way diminished. The size of the electronics sector is even more important today than it was in 2003, it is, therefore, reasonable to keep this specific legislation to target the specific challenges of it. Not least considering the problems of electronic waste and the difficulties connecting it to a more circular European economy. There is, of course, room for improvement. Following the application of the RoHS directive, one of the key areas to look at is how the restricted substance list could be expanded. So far, it has proven incredibly difficult to add more substances. Still, the necessary tools are available, as could be seen when phthalates were finally included. This should have been done for even more hazardous substances. It is disappointing that it has not happened more frequently, especially since we know that stricter regulation of hazardous chemicals is encouraging the innovation and production of safer alternatives. The substitution of most harmful substances has not occurred at the expected pace. With this in mind, the Commission could consider revising the exemptions in the RoHS directive and consider where innovation has made alternatives to hazardous substances in some of these categories. For example, solar panels where cadmium is not used should replace the older technology when this is possible. Introducing sunset dates for specific substances, or for that matter exemptions, could be an efficient way to gradually move away from the most harmful substances and increase the rate of substitution.
Read full response

Meeting with Andrea Vettori (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and

3 Mar 2022 · Restrictions Roadmap and the CSS implementation

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

1 Feb 2022 · Innovation in the chemicals industry

Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

Background In line with the chemical strategy for sustainability, the EU has committed to reduce the presence of hazardous chemicals in FCMs. The draft regulation seems to set this priority aside and instead only focusing on increasing the use of recycled material which is to the aims set by the Commission to achieve a non-toxic circular economy and that FCMs should not contain hazardous chemicals. Allowing for hazardous content A main hurdle for using recycled material in contact with food is that it often contains hazardous substances and is thereby not suitable. In the draft regulation, it is proposed that novel technologies for plastic recycling would be allowed to operate at scale and market recycled plastics for FCM use in the EU prior to any assessment of their efficiency for removing hazardous chemicals. This clearly opens up to the placing on the market of FCM that expose consumers to all kinds of hazardous substances that could migrate into the food. The proposed changes suggest that the toxicity of these products should be evaluated after the placing on the market. It is unclear how this could be enforced, and how these already spread products should be retracted/collected to ensure even further exposure. The Precautionary Principal, a fundamental safeguard when regulating chemicals, clearly is not applied in the draft. Unclear what technologies that are suitable It is likely to assume that the draft proposal aims to facilitate the introduction of material from technologies that are referred to as chemical or advanced recycling. These technologies are very different, but the draft regulation offers no differentiation or discussion around the various challenges present depending on which technology that is used. The environmental impact and purity of the products produced in these different technologies can be very different, but this is not considered in the draft. There is, today, not sufficient data regarding the environmental footprint (carbon emissions), scalability or potential to remove hazardous chemicals for any of the different non-mechanical recycling technologies. Therefore, caution is needed when introducing or supporting any of these technologies, and there is a great need for further information before moving forward. Is it really recycled? In principle, the technologies we can assume this draft regulation aims to support are, as written above, not commercially available at scale. To be viable, some of the technologies base their business model on elaborate schemes to allocate credits from one plant to another. In some cases, there is not a physical connection between where the waste comes in and the product comes out, it could even be separate processes located in different countries. This means that the product only contains recycled material in theory. The regulation must ensure that this kind of make-believe claim is excluded. In order to do so, the proposal must address the terms ”chain of custody”, ”mass balance approach”, ”book and claim”/”credit transfer” and ”physical connection”. If the aim of the Commission is to stimulate the use of new technologies to increase the amount of recycled material, the least the Commission must do is to ensure that it is indeed recycled. Suggested changes To conclude, the draft proposal fails to ensure both the safety of the materials and that the recycled material does indeed stem from waste. It goes against the foundation of the Chemical Strategy for Sustainability as well as the Precautionary Principle. The proposal is very challenging, to not say impossible, to enforce both regarding proving that the material comes from waste and ensuring that it doesn’t contain hazardous substances totally unsuitable to be present in FCM. ChemSec encourages the Commission to take these fundamental aspects into account before proposing changes in regulation.
Read full response

Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

Bio-based plastics Biomaterials will certainly be part of the solution for a less fossil-fuel dependent society. However, there are issues to be considered if the use of bio-based materials is to become truly sustainable which makes the topic very complex. The first question to ask is how sustainable the sources really are. Our second consideration is that bio-based chemicals can still be hazardous. The third angle of this to take into account is that using bio-based plastics will not reduce the burden that plastic waste puts on the environment. All of the above is further explained in out attached document “How do bio-based materials fit in the circular economy?”. In addition, we want to ensure that any bio-based plastic does not come from sources competing with food production or occupying land use that could be used for food production. Nor that it will come from sources causing de-forestation. Regarding the degradation process, it is important that any bio-degradable plastic does not form micro plastic, nor that it forms hazardous intermediates. Biodegradable and compostable The lack of clear definitions of these two concepts is very unfortunate. Biodegradable means that an item can be broken down into smaller pieces by bacteria, fungi or microbes to be reabsorbed by the surrounding environment, ideally without causing any pollution. But this is problematic, since everything we produce can be called biodegradable because everything will break down, eventually. It is just a matter of time, unfortunately, in many cases, a very, very long time. So therefore, the use of the term biodegradable is not very helpful, especially not for consumers which want to make the green choices. Biodegradable plastics is considered the eco-friendly version of conventional plastics. However, it is not always the green solution it seems to be. For example, one study showed that biodegradable plastic bags were still able to carry a full load, three years after being discarded in the environment. So, there is really some doubt regarding how “biodegradable” these products really are. In the case of compostable, there is a European standard for compostable packaging: EN 13432. It requires that the packaging break down under industrial-scale composting conditions within 12 weeks. The key word here being “industrial” which means that only a small minority of compostable plastics can be put on your compost heap at home; the majority needs industrial or local authority composters, since the labeling “compostable” refers to the above-mentioned standard. And if compostable plastics get mixed up with the rest of your recycling, they could contaminate the lot. So, it is important to keep them out of your plastics recycling box. In summary, the lack of clear definitions to these concepts, biodegradable and compostable, is opening up possibilities for green-washing and false claims, as well as causing a lot of headache for consumers wanting to find sustainable products. Therefore, there is a clear need for new definitions, where the terms are clearly defined and easy to understand.
Read full response

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

25 Oct 2021 · Chemicals strategy

Response to EU Chemicals Strategy for sustainability - Revision of the Cosmetic Products Regulation

19 Oct 2021

We welcome the revision of the Cosmetic Products Regulation and the proposed way forward presented in the roadmap. In our view the roadmap cover all necessary issues to be revised to make sure the Cosmetics regulation is in line with the aims and ambitions of the Chemical Strategy. Inclusion of the generic approach to risk management, phase out of chemicals with environmental properties of concern, inclusion of the concept of essential use as well as of a mixture assessment factor are all in line with the aims set out in the Chemical strategy. We support to more efficiently protect both EU citizen as well as our environment from harmful chemicals in cosmetics. We also support to move the tasks from SCCP to ECHA to have a more coherent assessment of chemicals used in cosmetics. The roadmap does not mention the interface between Cosmetics regulation and REACH. It is important that applications covered by the Cosmetics Regulation are not exempted from REACH as it could lower the level of protection. These two pieces of regulation should both be applied in parallel.
Read full response

Response to Simplification and digitalisation of labels on chemicals (CLP, Detergents, Fertilising Products)

20 Sept 2021

ChemSec thanks the Commission for the opportunity to leave comments to the Inception Impact Assessment on the simplification and digitalization of labels on chemicals. ChemSec agrees with the general idea of creating a harmonized digital labeling system for chemical product information. It is evidently suboptimal if several parallel digital labeling systems are being developed, if they need to be harmonized at a later stage anyway. This is thus a proactive initiative by the Commission that ChemSec appreciates. Moving forward there are some points that are important to keep in mind: 1. A digital labeling system cannot replace the current labeling system. Digital solutions can be convenient and desirable, but they can also create barriers. Therefore, it is important that products still contain relevant information to consumers. 2. A digital labeling system creates means to provide large amounts of information to consumers. If this is to be done, it is important that the information is well structured, harmonized, and easily understandable. Otherwise it will risk undermining the general goal of improving the health and safety of consumers. 3. A digital labeling system should be interoperable with other relevant databases currently in use for chemical substances, the SCIP-database that was introduced earlier this year could be one of them. Further on, ChemSec believes that simplification should in no way mean lower standards when it comes to providing information to consumers. In the Inception Impact Assessment, the Commission states that the easing of labeling requirements will reduce administrative burdens. ChemSec hope that this does not imply a desire by the Commission to reduce the amount of information provided to consumers, as it would be a move in the wrong direction. One of the insights from the many interactions ChemSec is having with industry is that more and better information as well as transparency on chemical content in products is desperately asked for. The opportunity to include more information in a digital format should be seized, and might lead to better operating supply chains all over Europe. Finally, the initiative should work hand in hand with the upcoming revision of the CLP-regulation.
Read full response

Meeting with Thierry Breton (Commissioner) and

24 Jun 2021 · Discussions on the implementation of the chemicals strategy for sustainability.

Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and European Environmental Bureau and

8 Jun 2021 · Chemicals Strategy for Sustainability and restriction roadmap

ChemSec demands tougher chemical registration and mandatory polymer notification

1 Jun 2021
Topic — The European Commission is revising laws governing the registration and evaluation of chemicals.
Message — ChemSec requests mandatory annual re-submissions of registration dossiers and stricter substance identification. They also advocate for registering all polymers and monitoring microplastic generation throughout their life cycle.12
Why — Implementing these strict requirements would help the organization reach its goal of a toxic-free environment.34
Impact — Industry players would face higher costs and potential market exclusion for failing to meet standards.56
Read full response

Meeting with Thierry Breton (Commissioner) and European Environmental Bureau and

5 May 2021 · Implementation of the chemicals strategy for sustainability

ChemSec urges EU to align food packaging rules with REACH

29 Jan 2021
Topic — This consultation reviews EU legislation governing chemicals in food contact materials.
Message — ChemSec wants a new regulatory framework harmonizing food packaging rules while aligning them with REACH. EU institutions should take greater responsibility for monitoring chemicals and informing citizens about health hazards.123
Why — A new framework would eliminate legal loopholes currently allowing hazardous substances in food packaging.45
Impact — Chemical manufacturers would lose the legal exemptions that currently allow them to use hazardous substances.67
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Dear Ladies and Gentlemen, please find our feedback attached. Warm regards Sonja Haider ChemSec
Read full response

Response to Sustainable Products Initiative

2 Nov 2020

ChemSec supports the Commissions ambition to address the prerequisites of producing sustainable products, in line with the Green Deal, the Circular Economy Action Plan and the Chemical Strategy. ChemSec is positive towards widening of the ecodesign directive beyond energy related products and the establishment of overarching product sustainability principles.To achieve useful and relevant principles it is essential to take a horizontal approach, while ensuring that it includes elements such as disclosure of chemical content and intrinsic hazard criteria. A very important pillar when setting principles and definitions is that a sustainable product, per definition, can not undermine other environmental objectives. This means, for instance, that a product that contains hazardous chemicals that can cause harm to human health and/or the environment can not be considered to be sustainable, even if it reduces CO2 emissions. One way to address this would be to apply the taxonomy principles, Article 3 of the EU Taxonomy regulation 2020/852. While a circular economy should allow for waste to be recycled into new products, it is in our opinion crucial to start with the design phase and recyclability rather that pushing for high levels of recycled content in new products. In order to build toxic free material cycles, the EU should be a market where new products do not contaminate the waste stream. Recycled content should be promoted, but never at the expense of introducing hazardous substances in the recycled material. Allowing recycling of hazardous materials in new products would cause “housefill” instead of “landfill”, while simultaneously undermining the public trust in recycled material. In addition, diluting hazardous recycled materials with virgin or non toxic recycled material would be a waste of high value resources.
Read full response

Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

6 Oct 2020 · Upcoming chemicals strategy Strengthening the EU’s chemicals regulation Import of especially hazardous substances Transparency requirements

Meeting with Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides)

16 Sept 2020 · VC meeting on Chemicals strategy

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

16 Sept 2020 · European Green Deal and the EU chemicals policy, including Chemicals Strategy for Sustainability

Response to Chemicals strategy for sustainability

12 Jun 2020

ChemSec welcomes the opportunity to comment on the Commission roadmap on the Chemical strategy for sustainability. The Green Deal from the EU Commission and its upcoming chemical strategy are long-awaited good news. The last couple of years, report after report have highlighted the importance of tackling the problem of hazardous chemicals and stressed the fact that it is an urgent matter. “Business as usual” is no longer an option, the issue of hazardous chemicals needs to be dealt with now. The EU Commission needs to assure that substances of concern are phased out from products and our society in order to protect human health and the environment – as well as to pave the way for a toxic-free circular economy. This will require major changes in industry that will not happen without powerful political measures. As a first step towards change, an ambitious chemical strategy is extremely important. We welcome the ambition put forward in the roadmap and would like to emphasise the importance for the strategy to include clear commitments, deadlines and deliverables to make sure the result is a more ambitious chemicals legislation. Following five important aspects needs to be included in the upcoming Chemical Strategy for Sustainability. 1. Support EU industry frontrunners 2. Speed up the regulatory processes and avoid “paralysis by analysis” 3. Strengthening the balance between generic and specific risk assessment in all EU chemicals regulations 4. Move towards full transparency and traceability -key for a toxic free circular economy 5. Close existing legislative gaps All points are further explained in attached paper.
Read full response

Meeting with Virginijus Sinkevičius (Commissioner) and

5 May 2020 · To discuss the importance of the Green Deal and Chemicals Strategy, and to address a some specific issues of the EU chemicals legislation

Response to A new Circular Economy Action Plan

20 Jan 2020

ChemSec and CHEM Trust call on Commission Circular Economy action plan to contribute to a toxic-free environment ChemSec and CHEM Trust welcome the consultation on the roadmap towards a new circular economy action plan by the Commission but are concerned by the missing consideration of the toxic-free environment objective set by the European Green Deal. Only if the action plan addresses the need to phase out substances of concern will a circular economy be successful. In 2018 the European Commission presented its Communication on the implementation of the circular economy package: options to address the interface between chemical, product and waste legislation. The Circular Economy action plan should build on this communication. We therefore call on the Commission to include following considerations into the Circular Economy Action plan: Phase out all substances of concern as input chemicals in products All substances identified as hazardous (by REACH, CLP and other relevant processes) have to be understood as substances of concern in a circular economy context and should thus be phased out as input into new products either via primary or secondary raw materials. One key problem is the movement from one hazardous chemical to another similar one that is less well understood and not yet classified as hazardous (e.g. bisphenols). Grouping of similar substances needs to address this issue. This means REACH as well as other chemical regulations needs to be implemented more efficiently and, in many cases, also revised to facilitate a clean circular future. Same standards for virgin as for recycled material It is in the greatest interest of all advocates of the circular economy that the quality of secondary material is maintained and does not become a new source of pollution. If not, reuse and recycling will not become an attractive option. Producers and downstream users need to be able to trust that the material they use is clean enough to keep customers safe and their brand reputations unharmed. The success of Circular Economy is therefore dependent on virgin and recycled materials that are free from hazardous substances. Traceability throughout the supply chain Traceability is key for the trust in recycled material. Few companies would buy recycled material without any knowledge about the chemical content. Many companies will require full insight in the chemical content to be able to trust it and for the material to comply with their internal standards. The substances of concern in products database (SCiP) currently developed by ECHA following the Waste Framework Directive revision is a step in the right direction. We suggest this database to be extended to include all substances of concern and to provide sufficient resources into the development of the database which can become useful for waste operators, consumers and regulators in their work toward a clean circular economy. Being able to provide brands with recycled material that is guaranteed to be free from substances of concern will be a major advantage to any waste management company short term, and a requirement in to future proof a company in the long run. Circularity by design We welcome the mention of a sustainable products policy for the action plan and emphasis to ensure circularity by design, which should include also the chemical content. Summary The circular economy will only be successful if it delivers on the zero pollution ambition for a toxic-free environment and if companies and customers – including the public – are confident in the quality of recycled material. If this confidence is removed, then the market will demand virgin materials, and the attempt to create a circular economy will fail. The removal of substances of concern is therefore key to achieve a successful circular economy.
Read full response

Response to Fitness Check on endocrine disruptors

20 Jun 2019

It could not come as a surprise that ChemSec - along with MEPs, Council members and other NGOs and stakeholders – find it a waste of time and resources to perform another fitness assessment, for EDCs. We are convinced that we have a good enough overview of the poor legal situation to move from analysis to action, and would ask the commission to do so. We would recommend the Parliament study from March 2019: “Endocrine Disruptors: from scientific evidence to human health protection” for a good overview of both scientific and legal developments in the field of EDCs in the EU. This overview should be enough to guide more concrete actions. It shows that for majority of the regulations there are insufficient definitions, guidance documents, test requirements and risk management logic. This is where the commission need to focus in order to have these regulations deliver on its objective to protect human health and the environment by minimizing overall exposure to endocrine disruptors. To repair is twenty times more difficult than to prevent. (Henri-Frédéric Amiel (1821-1881)) Truth is ever to be found in the simplicity, and not in the multiplicity and confusion of things. (Isaac Newton (1643-1727))
Read full response

Response to Restriction of CMR substances in textile articles and clothing for consumer use under REACH

8 Mar 2018

ChemSec comments to draft REACH Restriction of CMR substances in textiles ChemSec welcome the proposal from the Commission to restrict CMRs in textiles via 68(2) in REACH. Consumers need to be efficiently protected from hazardous substances and this proposal is one step in that direction. Production of textiles includes many harmful chemicals that can create harm at the production site but also in the use and waste phase. In our view a large part of the textile industry is well prepared for this restriction. For the ones not yet prepared this restriction will push them in the right direction. We encourage the Commission to continue to use the simplified procedure in REACH, 68(2), to protect consumers from CMRs. The process leading to this proposal for restriction of CMRs in textiles has unfortunately been very long which we regret since CMRs in textile is an urgent issue. We hope that this has been due to 68(2) being used for the first time and that the process will be more efficient next time. We have a few concerns regarding this draft restriction: Scoop is too narrow We would like to see all CMRs restricted in textiles since a specific list could be quickly out-dated when new substances come into use. The list included in the draft today consists of substances known to be found in textiles. A list of chemicals used in the textile sector is not static. We are concerned this list will be out-dated very soon. A specific list, like the one proposed here, might lead to regrettable substitution, which would be very unfortunate. We understand the need to have a list of specific substances from a company perspective. They need to know what to communicate to their suppliers. Instead of having a static list in the restriction we propose to have such a list in a guidance document which would make it easier to update and at the same time avoid regrettable substitution. Concentration limits too high In some cases the concentration limits are much higher than in previous draft. We cannot find any explanation to why and envisage the Commission to change these limits back to what was originally proposed.
Read full response

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

28 Jun 2017 · REACH