- highlights that while it is possible for the EU to propose an update to the United Nations Globally Harmonized System (UN GHS) in line with the revised CLP Regulation, there is no guarantee that the EU proposal will be accepted by all parties. A temporary divergence could become a long-term issue. It seems it would be virtually impossible to implement the new proposals regarding online sales originating outside the EU unless it is accepted by the UN GHS.
- believes that it is vital that the European Chemicals Agency (ECHA) has sufficient resources, expertise and staff to implement the revised Regulation. In particular, adding new hazard classes will require the ECHA and Member States to increase their resources to specifically handle the increased workload.
- regrets that there is no specific provision to alert the consumer in the situation where the chemical ingredients in a branded product are changed but the brand name remains the same. The consumer should be alerted to such changes where the brand name remains the same.
- suggests that the Commission's framework for monitoring the implementation of the revised CLP Regulation needs to carefully evaluate the impact on essential value chains involving chemicals so that they are not negatively impacted. The European Chemical Industry Council (Cefic) suggests that as many as 12 000 substances might be affected by the proposed changes to the CLP and the GRA (generic approach to risk management). As a result, many products that consumers and professionals rely on may no longer be available on the market.
- calls for particular attention to be devoted to the well-being of those who work in the chemical industry. Health and safety must always be prioritised. Workers in the chemical industry must be given intensive training so that they have a full understanding of the chemicals that they are in contact with in their work. All equipment needs to be properly maintained.
- stresses that the precautionary approach is important in the protection of health and the environment.