Reiteration of the major negative impact on industry of the current CLP proposal regards minimum requirements for labelling playlist_play

As a follow-up of the industry cross sector group letter of 5 September 2023, today industry released a new joint letter to reiterate the major negative impact on industry of the current CLP proposal as regards minimum requirements for labelling. In the new letter industry invites legislators to keep an open mind going in the trilogue discussions regarding minimum font size requirements.

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EFCC position on the European positive list under the Drinking Water Directive playlist_play

Today EFCC submitted its position in reply to the public consultation on the delegated act that supplements the Drinking Water Directive and that lays down the procedure for amending the European positive list of starting substances, compositions or constituents to be used in the manufacture of materials or products intended to be in contact with drinking water. EFCC is concerned that the increased data collection and analytical requirements planned to be required for the positive listing will put a significant burden of the manufactures and downstream users. In addition to this, EFCC considers that neither the DWD nor this implementing act provide sufficient protection for the shared data and confidential business information and as such is not protecting the intellectual property of the European economic operators. As downstream user formulators we fear that the number of applicants for the positive listing will be very limited resulting in a lack of substances available for drinking water materials after 2025. This would lead to a significant reduction of construction products available for drinking water installations which could put the distribution of the drinking water to European consumers via the pipe systems at risk.

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EFCC joins cross-sector call for a rethink regarding CLP revision playlist_play

EFCC together with several industry federations calls for urgent dialogue and a rethink regarding CLP Revision. We focus on three key aspects that will have a major negative impact on industry and the environment: - he new 6-month timeline for label updates instead of the 18 months transition period provided in Adaptation to Technical Progress (ATP) to CLP for harmonised classifications to become mandatory - the tabled amendment within the European Parliament to prohibit environmental claims on mixtures classified as hazardous or carrying supplemental labelling - the proposed requirement of a minimum font size - we suggest to follow ECHA’s guidance of 1.2mm x-height as the minimum font size

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EFCC position on the data handling aspects of the revised Construction Products Regulation (CPR) playlist_play

EFCC supports the key objectives of the Construction Products Regulation (CPR) revision, and in particular the ones aimed at addressing the shortcomings of the current rules, enhancing the sustainability of construction products and contributing to the objectives of the green and digital transition of the European economy. However, EFCC members have been concerned about the planned introduction of a significant number of additional data sharing requirements. Members consider many of the additional data sharing requirements as not improving the accessibility of relevant digital product information for citizens and authorities, whilst adding a very significant administrative burden on the construction chemicals industry.  

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EFCC with other DUCC members released the last statement before the Council vote on the revision of the CLP playlist_play

Tomorrow the European Council votes on the compromise proposal on the revised EU legislation on hazard classification, labelling and packaging of chemicals (CLP). EFCC with other downstream user associations reiterated their concerns related to the revised proposal. We request more flexibility on the labelling requirements and reasonable transition periods for the application of the new criteria. You can read more details below.

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Cross industry request for a phased implementation of the Mixture Allocation Factor (MAF) playlist_play

EFCC members have expressed many times their concern about the planned introduction of the Mixture Allocation Factor (MAF). Now, in June 2023, we reiterate this concern together with all DUCC member associations and SMEunited. We voice again that even a proposed MAF of 5 will have substantial impacts on the entire chemicals value chain, with serious knock-on effects on EU competitiveness and sustainability-driven innovations and only with very limited contribution to the safer use of chemicals and in most cases no benefits to end-users and society. If the MAF is introduced regardless of the concerns, we ask for its phased, stepwise, implementation and starting with substances with the greatest potential to contribute to unintentional co-exposure. 

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EFCC supports the joint statement on the draft Taxonomy Environmental Delegated Act playlist_play

EFCC, as member of the Construction 2050 Alliance, supports the joint statement of its members on the draft Taxonomy Environmental Delegated Act published in April 2023. For the construction sector the recommendations of the draft Environmental Delegated Act show fundamental weaknesses in terms of the usability and practicability . Read more details below:

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EFCC reaction to the EC (WSP) report (April 2023) on the Essential Use Concept playlist_play

EFCC together with other ASMoR members presents its first reaction to the WSP report supporting the European Commission in developing an Essential Use Concept published in April 2023.  The study and more specifically Appendix C do not fully reflect established facts nor contributions made by ASMoR and its members during the consultation. We would like to highlight the following:  uses of most hazardous chemicals can be safe and, by discarding the possibility of ‘safe uses’ from the impact assessment, WSP is not giving the full picture of the consequences we object to extending the scope of the Essential Use Concept to industrial uses; contrary to what WSP states in the study, the EU’s chemicals strategy for sustainability (CSS) proposed it application to consumer uses and to a certain extent to professional uses ‘safe use’ has not been defined so far and we are willing to contribute to defining it.

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EFCC's joint position with DUCC on the revised CLP playlist_play

EFCC together with other Downstream Users of Chemicals Coordination Group (DUCC) members formulated its concerns about the new requirements of the revised Regulation on classification, labelling and packaging of chemicals (CLP).

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