RUCODEM - Romanian Union of Cosmetics and Detergents Manufacturers
RUCODEM
a) promotion of the principles and standards required by the specific market concerning the production and distribution of cosmetics and detergents and household care products.
ID: 477429147901-47
Lobbying Activity
Response to Revision of the EU explosives precursors legislation
20 Aug 2024
We appreciate the launch of the public consultation and the opportunity to present our point of view on the regulations that are applicable in the area of explosive precursors with view to reducing the administrative burden and strengthen even more the safety. Regarding Option 2, we support it, as it is focused on strengthening awareness-raising and research. For example, we think it is needed to study more in depth of the extent to which consumer mixtures like detergents and cleaning products that contain low concentrations of explosive precursors, are in fact used for illicit synthesis. There are more concentrated sources that can be bought readily available. The research could help to explore whether the 1% concentration for explosive precursors in mixtures with more than five components may be too low or could be increased to a high threshold, for example 5%. In the same time it would helpful to determine whether current checkings, under article 8 of the Regulation, on professional clients are fit for purpose. Producers of Industrial & Institutional cleaning products need in present to contact yearly thousands of customers (e.g. in the area of food and beverage processing plants and not only) to check they are operating legitimately and not producing explosives. This is involving human resources to deal with administrative burden aspects which do not add the aspects regarding safety. Instead should be explored if there could be an alternative procedure to fulfill the protection but to reduce the administrative burden. At national level exists a register that has to be filled in by each economical operator implying human resources and time. Having it online, and functioning, would help much more in the evidence and cross checking that the authorities want to have on transactions with explosive precursors. Regarding Option 3 by which it is mentioned the introducing of new measures and expansion of the chemicals regulated, without determining first if the existing measures are appropriate we estimate that many professional and household cleaning products could be dramatically impacted by those changes. Therefore the attention should be on improving the parts of the Regulation that are regularly raising doubts about their correct interpretation (e.g. inspection during sales, identification/reporting of suspicious transactions such as orders from a person/company that is not known to have a legitimate use for the chemical).
Read full responseResponse to Streamlining EU scientific and technical work on chemicals through the EU agencies
2 Apr 2024
RUCODEM comments on several aspects of the legislative proposals on the establishment of a CDPC and on the re-attribution of scientific and technical work to ECHA regarding: Definitions - some need to be clarified: definition of environmental sustainability related data (too broad and is not clear to which information it refers to); definition of chemicals data; the definitions of duty holder and business operators (clarification to distinguish the difference between them), need to add a definition of study (studies generated as part of the regulatory obligation for those cosmetic ingredients to be reviewed by the SCCS - studies to be notified should be limited to those relevant for hazards/risk identification) and would be relevant to define a list of studies to be notified (including for which hazard endpoint of interest, with indications regarding clear acceptability standards and criteria for the studies). Also a clarification is needed on the delegated power given to the EC to add new categories of data types. Confidentiality access and use of data, and the protection of confidential information under the originator principle as foreseen by the actual draft, it is understood that the current practice regarding the confidential information submitted to the SCCS would be maintained and guaranteed (the public will have access to chemicals data contained in the CDPC when such information was already disclosed in accordance with EU legislation based on which data was submitted). Attention should be given also by ECHA to the protection of IP in the CDPC, especially as some data will be made publicly available. SCCS specific role and expertise SCCS needs to continue to work as a separate committee within ECHA. Re-allocation of SCCS work to ECHA should support the specific and particular expertise of this body that was gained over the years on the safety of cosmetic ingredients and products; this can be obtained only if the SCCS will remain a separate committee within ECHA. The re-attribution of SCCS work should ensure that the in-depth expertise gained during the years by existing entities is preserved. The knowledge of the SCCS to perform risk assessment without animal use should be preserved. Transparent safety assessment evaluation for cosmetics should continue to be marked by the use and further development of the current SCCS Notes of Guidance. The move of the SCCS work to ECHA could represent the opportunity to promote risk assessment methodologies based on non-animal data beyond cosmetics. It is important that the implementation of an OSOA approach should consider the aspect that cosmetics and cosmetic-only ingredients do not undergo testing using animals. Harmonising hazard data and move to a OSOA approach may have sense, but risk assessments are critical and most relevant to EU consumers and should further be the decision-making process since it requires consideration of specific and realistic scenarios for product exposure. Harmonisation focused on making regulatory decisions based on a hazard approach only will not have as result a better consumers protection.
Read full responseMeeting with Rovana Plumb (Member of the European Parliament)
27 Sept 2023 · CLP revision-APA level