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Brussels, 2 October 2001
Euro Coop's Comments to the European Commission's White Paper:
"Strategy for a future Chemicals Policy" (COM (2001) 88)
Euro Coop is the European Community of Consumer Co-operatives, whose members are the national organisations of consumer co-operatives in 11 of the 15 Member States of the EU and in 4 Central and Eastern European countries. Created in 1957, Euro Coop today represents over 3,200 local or regional co-operatives, membership of which amounts to over 19 million consumers in the EU and 2 million in the associated countries of Central and Eastern Europe.
Euro Coop welcomes the European Commission's White Paper: "Strategy for a future Chemicals Policy" (COM (2001) 88) and sees it as an important element of the actions identified in the 6th Environmental Action Programme.
Euro Coop has for many years called for a revision of the EU Chemicals Policy in order for it to better protect the environment and human health. The current system is not working well. The control and classification of existing chemicals under the system is too slow and inefficient.
Therefore Euro Coop believes that any strategy and hence legislation must be based on the Copenhagen Charter's five demands, which are:
- A full right to know, including what chemicals are present in products.
- A deadline by which all chemicals on the market must have had their safety independently assessed. All uses of a chemical should be approved and should be demonstrated to be safe beyond reasonable doubt.
- A phase out of persistent or bio-accumulative chemicals.
- A requirement to substitute less safe chemicals with safer alternatives.
- A commitment to stop all releases to the environment of hazardous substances by 2020.
As well as, the following two principles: The precautionary principle and the polluter pays principle.
Furthermore, Euro Coop is of the opinion that the following two elements must be included in the Strategy:
- A risk assessment approach, which tackles "generic" groups of chemicals, rather than the current substance-by-substance approach. The current approach costs too much both in time and in resources.
- A comprehensive approach to chemicals, focusing on their use, dispersion and disposal throughout product life cycles and not just on impacts during chemical production.
Besides Euro Coop has the following specific comments to the White Paper:
1. Information and Labelling:
Euro Coop agrees that there is a necessity for information to the public in order for consumers to make an informed choice between products. Therefore consumers should have the right to know of the constituents in products. In addition, safety data should not be considered confidential. They should be available to the public.
However, the White Paper does not address how to involve the consumer more actively in the process.
One way could be through educational measures, such as information campaigns and leaflets, in order for the consumers to better understand the problems connected to chemicals. For instance, guidance on how the consumer best doses washing powder properly in order to protect the environment.
It is one thing to decide by reading the label to see what chemicals are contained in a product. But it is a completely different thing how best to use the product in order to protect the environment and human health.
Another way is through a simple and comprehensible labelling system. Nevertheless, labelling must not be misused by industry in terms of using it as an excuse to push the responsibility over to the consumers by saying it is their choice. The industry is still responsible for the content and correct disposal of the products.
2. The REACH System:
Concerning the White Paper's proposal for an expanded European Chemicals Bureau in order to have a central entity to deal with the administration of the REACH-system. Euro Coop supports this proposal but would like to call for adequate financial means and personnel in order for the Bureau to be able to deal properly with the administration of the system.
However, the REACH system should not become a license to continue using risky chemicals. Therefore it is necessary to stress that the system is intended to ban risky chemicals except in specific cases where it can be proofed that there is a public need and no safer substitute.
Furthermore, the last paragraph on Action 3E in the White Paper is unclear. The substances in products should not be left for the working group to identify and decide upon. This should be part of the REACH system. For that reason, Euro Coop calls on the European Commission to clarify this paragraph.
3. Review of Strategy:
The White Paper does not propose any date for reviewing the Strategy. Euro Coop calls for a date to be inserted, preferably in five years time after the legislation has entered into force. In this way the strategy can be adjusted according to the experiences gained.
Contact: Louise Ousted Olsen, Acting Secretary General
Tél.: 02.285.00.76 - Fax: 02.231.07.57 - e-mail: Lousted_Olsen@eurocoop.org
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