Joint letter: Urgent Need for a Harmonised and Workable Approach to Substances of Concern
On behalf of a broad coalition of European industries and in light of the European Commission’s commitment to delivering regulatory simplification and boosting the competitiveness of European industry, we are writing to express our significant concerns and recommendations on the “Substances of Concern” (SoC) provisions. In particular, under the Ecodesign for Sustainable Products Regulation (ESPR), and the Corporate Sustainability Reporting Directive (CSRD), and other legislation.
While we are fully committed to the objectives of enhancing product sustainability and promoting a circular economy, we urge the Commission to ensure that regulatory provisions on substances in products and related information requirements remain targeted, risk-based, and aligned with the existing legal framework on chemicals and waste.
In the context of the upcoming Omnibus packages, we ask the Commission to take into consideration our key concerns and recommendations to ensure that the EU environmental acquis is both environmentally effective and practically implementable.