Revision of the CLP regulations: our proposals to keep on track on the non toxic environment
The Chemicals strategy aims at strengthening the EU legal framework to address pressing environmental and health concerns through the revision of the REACH and CLP Regulations. Following the impact assessment and roadmap, the Commission consulted citizens and stakeholders as part of the targeted revision of the CLP regulation. Our particular position at the interface between products, chemicals and waste has given us specific experiences to share concerns and proposals on the revision of the CLP regulation in order to protect health and the environment and pave the way towards a non toxic environment. You will learn below our main points: Our main challenge is to acknowledge the distinction between waste and products, justifying different approaches between them and the relevance to keep separate classification. As stakeholders acting at the very end of the economic chain, our experience demonstrated that once a product becomes waste, it is not always easy to know for sure its final destination. A product is designed for a known specific use, with a use scenario, making it relevant to apply a risk based approach that will validate that there are no adverse risks for this use. On the contrary, a waste could not be oriented for sure towards one expected route and many different choices are available between recycling, recovery or disposal, depending on the quality
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