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
To pave the way towards « a zero pollution ambition for a toxic-free environment », the EU Green Deal annonced the objective of the EU commission to look more systematically at all policies and regulations and adopt in 2021 a zero pollution action plan for air, water and soil. Find HWE’s proposals to ensure that our legislation and principles reach this objective of a non toxic environment :
Announced in the EU Green Deal as part of the actions to support zero pollution, the forthcoming European Chemicals strategy for sustainability represents a valuable opportunity to pave the way towards a non toxic environment. As HWE, we have developed 8 points to reach this objective – that you wil find further detailed in the paper: define substances of concern adopt a grouping approach integrate missing hazards in the relevant legislation ensure traceability ban dilution guarantee clean material cycles through decontamination keep the hazard based approach for waste support ECHA work Download the paper:
In the framework of the fitness check of the EU rules regarding harmful chemicals, HWE answered the stakeholder’s consultation on endocrine disruptors. The adoption of a comprehensive and integrated framework on endocrine disruptors, common criteria to define them independently of the sector of activity and the creation of a specific hazard in the CLP regulation will contribute to deliver a zero pollution ambition for a toxic-free environment to protect health and the environment. Please click on the contribution to read HWE’s position.