On May 24, 2016 the European Consumer Organisation (BEUC) and the European Association for the Co-ordination of Consumer Representation in Standardisation (ANEC) released a position paper on the European Commission’s (EC) fitness check on chemicals legislation (excluding REACH). From March 4, 2016 to May 27, 2016 the EC held a public consultation on the regulatory fitness of EU chemicals legislation to obtain stakeholder views on the functioning of the legislative framework for chemicals (FPF reported). The fitness check does not cover the regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), however it includes, among others, food contact materials (FCM) regulations (EC) No 10/2011 and (EC) No 450/2009.
In their position paper, ANEC and BEUC express concern that “this exercise could weaken vital legislative provisions that exist to protect consumers, workers and the environment.” They claim that the fitness check is by design biased towards industry views and interests, focusing mainly on “identifying regulatory burdens to industry, quantifying costs, and eliminating redundancies.” Exemplifying this, ANEC and BEUC highlight that the fitness check’s examination of risk management approaches focuses strongly on costs to industry, rather than on consumer protection. This could lead to the conclusion that “hazard-based standards are disproportionately burdensome to industry,” which the two organizations deem unacceptable in regard to protecting consumers from harmful chemicals.
ANEC & BEUC (May 24, 2016). “Regulatory fitness check of chemicals legislation except reach – A consumer view.” (pdf)