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EGMF, together with 30 other industry organisations, acknowledges the proposal on essential uses in the Chemicals Strategy for Sustainability (CSS) and welcomes the policy debate that has arisen regarding the Essential Use Concept (EUC). It is encouraging to see that suggestions in the ensuing policy debate point to creating a framework for applying the EUC, rather than simply a black and white listing of uses, and that its application will require a case-by-case assessment. However, even with such a framework and case-by-case approach, we have concerns that introducing the EUC could adversely affect regulatory efficiency and negatively impact safe uses of articles and overall sustainability. In this paper, we outline our thinking about a scope of application of the EUC that would account for some concerns.

The clarification of the scope of application is especially important as the Montreal Protocol, which inspired the ongoing policy debate, has a much narrower scope and addressed unacceptable risks (not simply hazard). The initial proposal of the Commission in the CSS was to apply the EUC purely on a hazard-basis, i.e. to all ‘most harmful chemicals’ and to ban their consumer (and professional) uses, except essential ones, regardless of whether they present a risk.

To read our recommendations in full, please download the document.

EGMF co-signed an industry statement, together with 9 other associations, calling on the European Commission and the co-legislators to ensure a transition period for the implementation of the Batteries Regulation.

We support the European Commission’s objective to improve the sustainability of batteries, while protecting the competitiveness of the Single Market. We are fully committed to supporting the EU’s transition towards sustainable batteries.

While interinstitutional negotiations are yet to begin, it is already clear that the new Batteries Regulation will have far-reaching impacts on the design, labelling and end-of-life handling of batteries and battery-powered appliances. Given the extent of the changes and the significant uncertainty over the final text of the Regulation, we call on the co-legislators to provide economic operators with the necessary time to duly implement due requirements. This is particularly pertinent for all those market access, CE-mark relevant provisions with design or labelling impacts that currently are foreseen to apply as of entry into force (e.g. Art. 11, 20).

We recommend to:

• Introduce a transition period to ensure individual provisions are applicable no earlier than 24 months after the adoption of the corresponding Guidance, delegated or implementing act; and

• Introduce a 24 month transition period (Art. 79 or 78 of the proposal) between the entry into force of the Regulation and its application, by replacing the current date of application that is set for 1 January 2022.

We remain strongly committed to working together with the European Commission and the co-legislators to ensure that the review of batteries legislation becomes a success.

You can read the full Joint statement on Batteries Regulation here.