Zveza potrošnikov Slovenije
ZPS
ZPS - Slovene Consumers’ Association is an independent and autonomous non-governmental organization dedicated to protection and representation of consumer interest as well as to providing impartial advice and education to consumers.
ID: 127396426409-40
Lobbying Activity
Response to The protection of waters against pollution caused by nitrates from agricultural sources – Evaluation
8 Mar 2024
ZPS pozdravlja namen EU komisije za prenovo direktive varstva voda pred onesnaževanjem z nitrati iz kmetijskih virov. Direktiva je v luči zelenega dogovora, kakor tudi že uvedenega principa »poluter pays« nujna. Pripenjamo obširnejšo razlago.
Read full responseResponse to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials
8 Mar 2024
ZPS Comments to COM consultation on Food safety restrictions on bisphenol A (BPA) and other bisphenols in food contact materials Zveza potrošnikov Slovenije, ZPS (Slovene Consumers` Association) is a non-governmental organization promoting strict restriction of harmful endocrine-disrupting substances and generally advocating for toxics-free materials and products for over 30 years now. We welcome the proposal for revising the Packaging and Packaging Waste Regulation that includes the ban on Bisphenol A. We also appreciate the provisions to ban other bisphenols to prevent regrettable substitution. As an organization working with consumers and responding regularly to their concerns about hazardous substances in food, packaging, and consumer products, we are often faced with disappointment that food packaging contains several unregulated substances that leach into the food, water, and environment. In several surveys conducted independently or as part of Life-funded projects, consumer organizations many times voiced their demand to ban these substances immediately. They are even surprised that substances recognized as harmful and classified as toxic to people are still allowed in food packaging as well as other products. One of the most recent analyse performed by consumer organizations from several EU countries (Austria, Belgium, Czech Republic, Denmark, France, Italy and Slovenia) led by International Consumer Research & Testing (ICRT), revealed high levels of BPA and other bisphenols not only in a variety of children's products, but also in large concentrations in canned food and drinks. Main findings and brief summary is available on the BEUC web site. In the analysis we found that all the 35 tested food cans and the 23 soda cans contained between 1 to 6 different bisphenol-related compounds. BPA was found in all 23 soda cans. In almost all samples of food cans, except two bought in France, BPA was one of the bisphenols detected. Last but not least, as the recent Horizon 2020 research initiative, HBM4EU, revealed that 92% of Europeans from 11 EU countries were contaminated with BPA residues in their urine, the legislators must act NOW and take all the measures to reduce the burden of such toxic endocrine disrupters contributing to severe health problems including increasing rates of infertility and breast cancer. In light of EFSA´s recent re-evaluation of the safety of BPA as used in FCMs from April 2023 when the tolerable daily intake levels were lowered 20,000 times, we strongly support the restriction that shall be adopted with no exemptions and for the entire class of bisphenols. By banning bisphenols (and ideally, PFAS too, which are regrettably not part of this public consultation), the EU will contribute to creating materials cycles that are toxics-free and easier and safer for recycling or reuse. To achieve this, we recommend that the final restriction: bans the intentional use of BPA in all food contact materials and articles, bans all bisphenols meeting the criteria for classification in any of the hazard categories listed in Article 4.1., enables effective Member State enforcement, extends the monitoring and reporting obligations to all bisphenols covered by Article 4., ensures a swift phase out of BPA and other bisphenols from food contact materials and articles. All measures are explained in more details in BEUC statement, which we strongly support. This submission is delivered as part of the project n. 101114078 LIFE22-GIE-HU-ToxFree LIFE for All where consumer associations from Hungary, Slovenia, Czechia, and Austria plus Arnika are working on raising awareness among consumers to change their behaviour and choosing toxics-free products and materials.
Read full responseResponse to Revision of the Toy Safety Directive
30 Oct 2023
Together with partner organizations, ZPS, Slovene Consumers Association is happy to see the draft Toy Safety Regulation (TSR) better protects children against harmful chemicals and reducing the risk of non-compliance. Especially, we would like to express our strong support banning known and suspected endocrine disruptors, respiratory sensitizers and STOTs. Further, the TSR will enable protective limits to be set for all toys. We recommend reinforcing the obligation in Art. 49 to consider exposure from toys and all other sources. Likewise, ECHA should be required to consider potential combination effects in its opinions. The new limits for nitrosamines and nitrosatable substances should be extended to all toys. A Digital Product Passport can facilitate enforcement and reduce the prevalence of non-compliant toys on the EU market. Safeguards are however needed to ensure the accuracy of the information and a well-functioning tool for all actors in the supply chain, consumers, and authorities. We agree on a free access by consumers but with data structured in the clear way and without requiring them to install specific apps or to register with personal data. Data processing shall be based on consent with consumers having to opt in. To safeguard childrens health and well-being, we further recommend the following: NON-CHEMICAL RISKS As the TSR rightly extends toy safety requirements to childrens mental health, we think we should pay a special attention to the interactive software, including computer and smart phone games either specifically designed for and targeted at children or that can be reasonably expected to be played by them, which are currently not covered. The proposal should cover threats from smart toys, too, as well as establish specific safety requirements for other risks, such as mechanical or physical risks. Based on the principle the higher the risk, the higher conformity assessment procedure, EC-type examination for smart toys and other toy categories should be included. Limits for sound emitting toys should be introduced. The overlap between toy and non-toy scooters should be further clarified. TOY LABELS AND WARNINGS The TSR will enable manufacturers to replace the word Warning with a pictogram. To avoid consumer confusion, it should provide for a single pictogram to be used. To make toy labels work for consumers, clear legibility criteria in relation to e.g. minimum font size or text/background contrast should be added. The obligation to include in the label a full ingredient list should be extended from cosmetic toys to toys that are substances or mixtures. ONLINE SALES Given their central role in the supply chain, the TSR should introduce a possibility to hold online marketplaces liable for non-compliance where no other responsible economic operator can be identified or takes appropriate action. Online marketplaces should be obliged to verify the identity of sellers on their sites, as well as to detect, remove and prevent the (re)appearance of non-compliant toys. Additional obligations for Very Large Online Platforms under the DSA should be set regarding the systemic risks related to the appearance of non-compliant toys. GOVERNANCE We welcome the new European Commission's powers to specify/amend certain TSR provisions and to address emerging risks. The precautionary principle should be reintegrated in the legal text to guide the regulator in situations where there are reasonable grounds for concern, but scientific evidence is insufficient or uncertain. Enforcement capacities should be strengthened, especially at national level, and the reporting of toy-related accident and injury facilitated by the setting up of a pan-European database. Joint market surveillance actions should be conducted. The proposed transition period should significantly be reduced.
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