In an article published on December 20, 2018 by regulatory news provider Chemical Watch, editor Leigh Stringer informed about an open letter sent by 41 European non-governmental organizations (NGOs) to the European Chemicals Agency (ECHA) on December 12, 2018. The letter concerns the database of substances of very high concern (SVHCs) in products that is being developed by ECHA (FPF reported) as required by the new EU directive on waste (FPF reported).
Industry has already outlined its position on the proposed SVHC database in a joint position paper released on October 24, 2018, claiming that the information requirements are too high and need to be reconsidered (FPF reported).
In response, the NGOs point out that industry “has had to know about the location and concentration of . . . [SVHCs] present in its products for over a decade” already. Therefore, the “responsible industry reaction is to help put . . . [the database on SVHCs in products] in place rather than asking ECHA to reconsider its creation.” Therefore, the NGOs call on ECHA to “remain determined” and to ensure that industry does provide all the information necessary to “achieve the objectives set by the EU legislators and to achieve a non-toxic circular economy.”
A similar position has been expressed by Martin Fuehr from the University of Applied Sciences, Hochschule Darmstadt, Germany, in an opinion article published by Chemical Watch on December 7, 2018. He called on industry to “consider whether they base their strategic approach on Augeas’s habit of idleness or start to clean up their supply chains in order to be prepared not only for January 2021 [(when SVHC reporting requirements come into force)] but also for the market challenges deriving from enhanced traceability and transparency on substances in articles.”
Leigh Stringer (December 20, 2018). “NGOs rally against industry’s call to scrap ECHA SVHC database.” Chemical Watch
Client Earth (December 12, 2018). “Open Letter: NGOs’ reaction to the ‘Joint industry position paper regarding the waste framework directive database.’”
ACEM (October 24, 2018). “Industry position paper regarding the database foreseen in the Waste Framework Directive.”
Leigh Stringer (October 31, 2018). “ECHA’s SVHC database requirements to be ‘within the law.’” Chemical Watch
Martin Fuehr (December 2018). “The modern Augean stable.” Chemical Watch
Clelia Oziel (December 11, 2018). “EU survey finds article suppliers lack information on SVHCs.” Chemical Watch
Leigh Stringer (December 12, 2018). “Funding negotiations could delay ECHA’s SVHC database.” Chemical Watch