FTA has provided comments to the European Commission Roadmap on the chemical, product, waste interface, which is of key importance for its members.
The roadmap identifies four main obstacles for a smooth transition of recycled materials from waste to new products to which FTA has several comments:
- Retailers, brands and importers have limited visibility on the substances used in the supply chain, notably in the absence of legal obligations for non-EU based suppliers.
- FTA opposes any increased obligation for chemicals that are not classified as Substances of Very High Concern as this will not ease compliance.
- FTA members believe that recycled raw materials should comply with all existing regulations on chemicals, including REACH.
- Expanding REACH authorisation requirements to imported articles in not a viable option. Similarly REACH restrictions can help phasing out hazardous substances but cannot drive innovation in the development of less hazardous substances as much as authorisation.
Interested in discussing this topic further? Please contact Malik Duhaut, Regulatory Affairs Advisor, to join our Working Group on Consumer and Environmental Affairs.