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Open letter to the Commission regarding transparency


Open letter to the Commission regarding transparency

Published on 20 Apr 2022

To the European Commission:

Frans Timmermans, Executive Vice-President – European Green Deal
Thierry Breton, Commissioner for the Internal Market
Virginijus Sinkevicius, Commissioner for the Environment
Mariya Gabriel, Commissioner for Research, Science and Innovation

We, the signatories of this open letter, urge the Commission to examine how to best incentivize chemical suppliers to share full information on chemical content and hazardous properties.

In the Chemicals Strategy for Sustainability (CSS), the Commission recognizes that a key to achieve the high ambition, is to support frontrunners in their substitution efforts.

The CSS states that “frontrunners still encounter major economic and technical barriers” and that “this transition needs stronger policy and financial support”.

Read our op-ed about this letter and the importance of transparency

It is fundamental that such support is fit for purpose and we therefore, as representatives of “frontrunner” companies, write this letter to offer our first thoughts and ideas on this.

We represent companies with an outspoken ambitious chemical management, aiming to be well prepared for and stay ahead of the developments in chemicals regulation.

We have found this to be a good strategy, and it is also what our customers expect from us.

There are, as recognized in the CSS, important barriers to overcome when taking this proactive and responsible approach to chemicals management. Policymakers can do more to support this development. We need both concrete actions as well as clear messages on the long-term direction and level of ambition.

With this open letter, we want to emphasise that there is one outstanding issue where your support could make the most difference in our strive towards proactive chemicals management and substitution of hazardous chemicals. This is to raise the legal obligations for transparency when it comes to information on chemical content and hazardous properties of chemical products, such as plastic resins, surfactants, or dyes.

Even for us influential, large, and multinational brands, it is challenging and often impossible to receive sufficient and relevant information from suppliers on the chemical content. We can only assume that this is even more difficult for SMEs.

While chemical producers are obliged to provide certain information about their products, for example in Safety Data Sheets, the information on hazardous properties is not sufficient and far from exhaustive. We need more information to be able to make informed decisions on chemicals, e.g., in relation to substitution of hazardous chemicals and their alternatives.

We recognize that both regulation and other incentives are important tools in creating real change. Indeed, the European chemical industry is today at the forefront of development, not in spite of, but in part because of, ambitious chemical legislation. In line with this, the Commission should introduce further demands and encourage more transparency.

There is a need to explore what tools could be used to further strengthen this development. This is also in line with the CSS where the Commission mentions the “lack of adequate information on the chemical content of products”.

Today, the primary information carrier is the Safety Data Sheet (SDS) which is regulated under REACH. Therefore, the most efficient way to increase the available information is to change the information requirements in the SDSs, to include more comprehensive information. We have provided some simple ways to do this below.

  • Information in the Safety Data Sheets shall be provided for each such substance that is present at a concentration equal to or greater than 0.01 % by weight.
  • Information should be provided for all substances that meet the criteria above, both classified and non-classified.

With this letter, we urge the Commission to examine how to best incentivize chemical suppliers to share full information on chemical content and hazardous properties.

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