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Muoviteollisuus ry, Plastindustrin rf

FIPIF

Muoviteollisuus ry on muoviteollisuuden, muovia raaka-aineenaan käyttävien, sitä jalostavien ja kierrättävien yritysten yhteenliittymä elinkeino- ja työmarkkinapoliittisissa asioissa.

Lobbying Activity

Response to Drinking water - conformity assessment procedure

16 Nov 2023

Comments: There appears to be a problematic difference between time tables of draft regulation related to conformity assessment (Ref. Ares(2023)7108760) and draft regulation related to establishing the European positive lists (Ref. Ares(2023)7108744). We ask the European Commission to assure that the proposed application date of draft regulation for conformity assessment is in line with end date of the transition period of draft regulation for establishing the European positive lists. In our opinion, the transition period for the new regulation in question here should be as long as possible. Comments are based on draft with reference "Ares(2023)7108760 - 19/10/2023" nad title "COMMISSION DELEGATED REGULATION (EU) /... of XXX supplementing Directive (EU) 2020/2184 of the European Parliament and of the Council by laying down conformity assessment procedures for products that come into contact with water intended for human consumption and the rules for the designation of conformity assessment bodies involved in those procedures"
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Response to Drinking water - establishing the European Positive Lists of starting substances

16 Nov 2023

Comments: We think that it is appropriate to set concentration limit values on conditions that there are generally available reliable analysis methods for their analysis and their setting can be justified by the results of up-to-date scientific studies. We would like to point out that these conditions are not fulfilled in the limit values that are proposed for PFAS starting substances and degradation products of stabilisers (pages 236 and 237 of Annex). We urge the European Commission to reconsider and postpone setting those limit values until noted conditions are met. In addition, we urge the European Commission to approve Finland's national positive list in full and add the zinc-loss-resistant brasses listed and reported by Finland to the European positive list. Comments are based on draft with reference "Ares(2023)7108744 - 19/10/2023" and title "COMMISSION IMPLEMENTING DECISION (EU) / of XXX laying down rules for the application of Directive (EU) 2020/2184 of the European Parliament and of the Council by establishing the European positive lists of starting substances, compositions and constituents authorised for use in the manufacture of materials or products that come into contact with water intended for human consumption"
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Response to Drinking water - procedures and methods for testing and accepting final materials

16 Nov 2023

Comments: We think it is appropriate to set testing requirements for the final materials as used in the products when the requirements have a justified connection to the actual use of the products. For this reason, we propose the European Commission to delete the requirement Multilayer products shall always be tested at 60 °C ± 2 °C or 85 °C ± 2 °C additionally, even when not used at these temperatures. from page 8 of Annex. In addition, for this reason, we propose to amend requirement Cold water test (23 °C ± 2 °C) shall be performed with chlorinated and non-chlorinated test water to Products that are normally used for chlorinated or non-chlorinated water shall be respectively tested with chlorinated or non-chlorinated cold water (23 °C ± 2 °C). on page 8 of Annex. We also think that testing requirements must be clear and must not give alternative methods. For this reason, we propose to amend page 10 of Annex by changing requirement For the enhancement of microbial growth (EMG) testing, standard EN 16421:2015 method 1 or 2 shall be used to For the enhancement of microbial growth (EMG) testing, standard EN 16421:2015 method 2 shall be used. In addition, for this reason, we propose defining term increasing trend clearly if it is used in requirements. Finally we think that it is not appropriate to set pass/fail criteria for unexpected substances until there are generally available reliable analysis methods for their analysis and criteria setting can be justified by the results of up-to-date scientific studies. We ask the European Commission to delete requirement 4.2.3. from page 13 of Annex until those conditions are met.
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Response to Drinking water - methodologies for establishing and amending the European Positive Lists

16 Nov 2023

Comments: We find Ctap and MTCtap maximum concentration limit value 0.1 µg/l so low that it will cause difficulties to implement some requirements of Directive (EU) 2020/2184. We think there is no availability of methods that could reach that low detection levels in required tests. We urge the European Commission to reconsider such low limit values and replace them with more realistic ones. In addition, we consider it problematic to require testing according to a certain method, unless the applicability of the requirement to the entire European Union area has been verified. We call on the European Commission to reconsider referring to methods that cannot be equally applied in all Member States. An example of such is the requirement to use a method whose test waters are not equally applicable everywhere (EN 15664-1, page 43 of Annex). Comments are based on a draft with reference "Ares(2023)7108735 - 19/10/2023" and title "COMMISSION IMPLEMENTING DECISION of XXX laying down rules for the application of Directive (EU) 2020/2184 of the European Parliament and of the Council as regards methodologies for testing and accepting starting substances, compositions and constituents to be included in the European positive lists"
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Response to Drinking water - Establishing the procedure for amending the European Positive Lists ('EUPLs')

13 Nov 2023

Comments: We propose to describe a procedure that, if necessary, gives possibility to make quick changes to the entries in the positive list. Urgent changes to the positive list may become necessary if new toxicological or other scientific information related to the entries is published. Comments are based on draft with reference "Ares(2023)7004776 - 16/10/2023" and title "COMMISSION DELEGATED REGULATION (EU) /... of XXX supplementing Directive (EU) 2020/2184 of the European Parliament and of the Council by laying down the procedure regarding inclusion in or removal from the European positive lists of starting substances, compositions and constituents"
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Response to Establishing harmonised marking to be used for products in contact with drinking water

13 Nov 2023

Comments: The proposed very detailed marking requirements would require an unnecessarily extensive repetition of the marking. The additional costs resulting from this would be difficult to justify in relation to the additional benefit that could be achieved. We propose reducing the marking requirements to a minimum. In addition, we point out that in the water glass shown in the symbol, the water surface is confusingly drawn with a wavy line. We propose drawing the water surface with a straight line. Comments are based on draft with reference "Ares(2023)7004793 - 16/10/2023" and title "COMMISSION DELEGATED REGULATION (EU) /... of XXX supplementing Directive (EU) No 2020/2184 of the European Parliament and of the Council by establishing harmonised specifications for the marking of products that come into contact with water intended for human consumption"
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