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CHEM Trust policy submissions and letters

2018

Response to the European Chemical Agency’s consultation on their plans for a database of SVHCs in articles, October 2018.

  • A CHEM Trust response to an ECHA consultation on creating a database of articles containing SVHC chemicals, as part of implementation of the revised Waste Framework Directive.

Comments on the UK Government’s plans for chemical regulation in the event of a no deal Brexit, July/Sep 2018

Response to EFSA’s consultation on MIXTOX Guidance, September 2018

  • CHEM Trust submitted a response to EFSA’s public consultation on the MIXTOX Guidance, a draft Guidance on harmonised methodologies for human health, animal health and ecological risk assessment of combined exposure to multiple chemicals,  September 2018.

NGO’s feedback on ECHA’s “Note on substance identification and the potential scope of a restriction on uses of ‘microplastics’”, September 2018

Letter to global government representatives demanding stricter standards on the plastic waste trade, September 2018

  • CHEM Trust co-signed an open letter calling for more transparency and regulation in the plastic trade. The letter has been delivered to world government representatives ahead of the working group meeting on Basel Convention (3-6 September 2018).

Letter to EC president expressing concerns about the EU proposal for SCCPs waste limits under the Basel and Stockholm conventions, September 2018

Letter to rapporteurs of the EU single-use plastic legislation regarding sanitary products, August 2018

Submission to the European Commission’s consultation on Roadmap for a new EDC Framework, July 2018

Letters to Commissioners and Member State representatives on the REACH committee regarding the proposed restriction on four phthalates, July 2018

  • CHEM Trust sent a letter to EU Commissioners Bienkowska, Vella, Andriukaitis and Timmermans, and co-signed (with European Environment Bureau), a second letter to Member State experts on the REACH committee, both calling for the proposed REACH Restriction on four phthalates to be extended to cover use of these phthalates in Food Contact Materials. The REACH committee letter has been covered by Chemical Watch and Food Packaging Forum.
  • Unfortunately the Food Contact uses were not added to the REACH Restriction; see also DG Grow’s reply to our letter to Commissioner Bienkowska.

Joint statement on Marine Litter and Microplastics, May 2018

Response to the European Chemical Agency call for evidence on the use of intentionally added microplastic particles in products of any kind, May 2018

  • CHEM Trust’s response to the European Chemicals Agency’s call for evidence on the use of intentionally added microplastic particles in products of any kind.

Response to Ökopol’s survey on specific PFASs (C4-C7) and other fluorinated substances (precursors or similar substances) to develop a restriction proposal under REACH, April 2018

  • CHEM Trust’s response to Ökopol’s survey on specific PFASs (C4-C7) and other fluorinated substances (precursors or similar substances) to develop a restriction proposal under REACH.

Letters to EU authorities on grouping of chemicals, in particular bisphenols, March 2018

Response to European Commission consultation on pharmaceuticals in the environment, February 2018

Comments on the consultation on EU Guidance for the identification of Endocrine Disruptors, January 2018

  • CHEM Trust submitted our comments to the European Chemicals Agency’s consultation on the EU Guidance for the identification of Endocrine Disruptors.

2017

Comments on the European Commission’s ‘Road Map’ for the evaluation of laws on chemicals in food contact materials, December 2017

  • CHEM Trust submitted our comments to the European Commission’s consultation on its proposed “Road Map” for the evaluation of the laws on chemicals in Food Contact Materials. All submissions are available from the Commission’s web site here.

Joint statement on the need for a ban on oxo-degradable packaging, November 2017

Nomination of priority substances for HBM4EU, November 2017

  • CHEM Trust proposed nominations for priority substances in the 2nd prioritisation round for the EU Human Biomonitoring Initiative HBM4EU. See our blog for further details.

Joint NGO letter to the Secretary of State for the Environment, Food and Rural Affairs, Michael Gove, on chemicals regulation after Brexit, October 2017

  • Joint letter from CHEM Trust and 18 organisations to the Secretary of State for the Environment, Food and Rural Affairs, Michael Gove, calling for keeping the UK in the EU main chemicals regulation REACH after Brexit, October 2017; and the response from the Minister responsible for chemicals regulation, Thérèse Coffey, November 2017

Response to follow-up UK Parliament Environment Audit Committee inquiry on Chemicals regulation and Brexit, October 2017

Response to European Commission consultation on Microplastics, October 2017

Joint NGO letter on to the EU on conflicts of interest in PFOA assessment, October 2017

Response to European Commission consultation on draft regulation on migration of BPA from food contact coatings and varnishes, September 2017

  • CHEM Trust’s response to a consultation on an EU Commission Draft Regulation on “Bisphenol A in varnishes and coatings and plastics intended to come into contact with food”.

Response to European Commission consultation on the “Chemical, Product, Waste interface”, July 2017.

  • CHEM Trust’s response to a European Commission consultation on the “Chemical, Product, Waste interface” interface.

Joint NGO petition “EU: do more for health!”, July 2017

Joint NGO statement on Sustainable Chemistry, May 2017.

Comments on ECHA consultation on identifying of Bisphenol A as human endocrine disrupter, April 2017.

  • CHEM Trust’s comments on the proposal to identify Bisphenol A as a Substance of Very High Concern (SVHC) on the basis of the Criteria set out in Reach Article 57.
  • We also submitted brief comments supporting the nomination of Perfluorohexane-1-sulphonic acid (PFHxS) and its salts as a very persistent and very bioaccumulate chemicals of very high concern.

Comments on the European Commission’s roadmap on the interface of chemicals, products and waste legislation, March 2017

CHEM Trust submission to the European Commission’s consultation for the 5 year review of REACH, January 2017

CHEM Trust submission to UK Parliament Environment Audit Committee inquiry on Chemicals regulation and Brexit, January 2017

Joint NGO letter to MEPs concerning the potential impacts of the EU-Canadian CETA trade agreement on the regulation of hormone disrupting chemicals, January 2017

2016

Joint NGO letter to European Chemicals Agency posing 7 key questions on the 10th anniversary of the REACH chemicals law, November 2016

  • A joint letter, signed by CHEM Trust, from European environmental organisations, asking for answers to seven questions on how the European Chemicals Agency is implementing the REACH chemicals law. This letter has been reported on by Chemical Watch.

Response to a UK Government consultation on updating furniture fire safety regulations, November 2016

Comments on a Draft report for UNEP, entitled “Overview Report I: A Compilation of Lists of Chemicals Recognised as Endocrine Disrupting Chemicals (EDCs) or Suggested as Potential EDCs“, September 2016

  • CHEM Trust submitted comments on this report, welcoming it and suggesting improvements.

Signatory to Global Vision for a Future Free of Plastic Pollution, September 2016

Submission to informal UK Health and Safety Executive Consultation on EDC Criteria, September 2016

  • CHEM Trust submitted a response to an informal consultation as part of the UK Government’s development of a position on the EU EDC criteria.

Joint statement on hazardous flame retardants in furniture, September 2016

  • CHEM Trust joined with other environmental groups, the European Furniture Industry Association, The European Fire Fighter Unions Alliance and others to call for improved furniture fire safety standards that do not require hazardous flame retardant chemicals.

Joint letter to EU Member States regarding a proposed restriction on PFOA-related substances, September 2016

  • A joint NGO letter to EU Member State representatives asking them to strengthen proposed restrictions on PFOA and related substances. Press release from IPEN here, more information on PFOA and other perfluorinated chemicals on our PFCs page.

Response to the EU Commission consultation on EDC Criteria, July 2016

  • Our submission is available here, and we have also written a blog about it.

Joint letter to EU Parliament President Schulz on TTIP, July 2016

  • A joint NGO letter to European Parliament President Schulz, expressing our serious concerns that the European Commission is failing to respect the European Parliament’s 2015 Resolution on TTIP. See also press release.

Joint letter to Commission President Juncker on EDC Criteria, June 2016

  • A joint NGO letter to European Commission President Juncker regarding the setting of criteria to identify EDC chemicals.

Response to the Commission’s consultation on the non-REACH REFIT, May 2016

  • A CHEM Trust response to the Commission’s consultation on the non-REACH Regulatory Fitness Check, or REFIT.

Joint letter to Commissioners Timmermans, Vella and Bienkowska regarding the non-REACH REFIT failing ‘Better Regulation’ guidelines, May 2016

  • A joint NGO letter to European Commission First Vice President Frans Timmermans and Commissioners Vella and Bienkowska regarding the ongoing non-REACH chemicals ‘Regulatory Fitness Check’ or REFIT, which is not following Better Regulation guidelines. This letter has been covered by Chemical Watch.
  • Within days of the receipt of this letter the Commission published their Roadmap for the non-REACH chemicals REFIT. Its file name starts ‘2015-‘, suggesting that it was completed some months ago.

Response to a consultation on CLP and related legislation, as part of the non-REACH REFIT, April 2016

  • A CHEM Trust response to a targeted stakeholder consultation on the regulatory fitness check for the Classification and Labelling (CLP) Regulation and related legislation, part of the non-REACH Regulatory Fitness Check, or REFIT.

Response to UK House of Commons Environmental Audit Committee inquiry on the environmental impact of microplastics, April 2016

Joint NGO letter to REACH committee regarding Bisphenol A and DEHP, April 2016

Joint NGO letter to UK MEPs on glyphosate, April 2016

  • A joint NGO letter to UK MEPs calling for them to vote to object to a proposal from the Commission to renew the authorisation to use glyphosate.

Joint NGO letter to Environment Ministers on Endocrine Disruptors, February 2016

  • A joint letter from the EDC Free coalition, including CHEM Trust, sent to EU Environment Ministers on 29th February 2016, asking them to call on the European Commission to set criteria to identify endocrine disrupters based on 3 categories.

CHEM Trust Briefing: Chemicals in food contact materials: A gap in the internal market, a failure in public protection, January 2016

Joint CHEM Trust and Greenpeace response to a consultation on the UK’s Chemicals Stakeholder Forum, January 2016

Joint UK NGO and Union letter to Commissioner Andriukaitis regarding setting criteria to identify EDC chemicals, January 2016.

  • CHEM Trust joined with health NGOs, the Unite Union, the Soil Association and the Land Workers Alliance to send a letter to EU Health Commissioner Andriukaitis about the issue of setting criteria to identify Endocrine Disrupting Chemicals. He replied to our letter in February 2016.

Joint NGO letter to President Juncker regarding the European Court of Justice ruling on the Commission’s failure to set criteria to identify Endocrine Disrupting Chemicals, January 2016

  • CHEM Trust, EEB, HEAL and PAN jointly sent a letter to President Juncker, copied to First Vice President Timmermans and Commissioners Andriukaitis and Vella, criticising the Commission’s inaction following the ECJ ruling.

Policy statements from previous years