Environment: Joint industry position paper on the concept of Essential Use

Published: 3 November 2021

Policies & Issues: Environment

Orgalim, 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 recommentations in full, please download the document above.

Authors

Tierny
Timothée Tierny
Adviser - Energy and Environment

Related Position Papers

Environment: Orgalim position on the upcoming revision of the REACH Regulation [13 April 2022]

Environment: Orgalim Position Paper on the “right to repair” [5 April 2022]

Environment: Orgalim Position Paper on the restriction of PFAS [27 January 2022]

Environment: Orgalim Position Paper on the draft French Decree on consumer information for waste-generating products [21 December 2021]

Environment: Joint industry position paper on the concept of Essential Use [3 November 2021]

Environment: Orgalim comments on the draft French Decree on the minimum proportion of reused packaging [28 October 2021]

Environment: Financing key enablers of the green transition: Orgalim position on the EU taxonomy for sustainable activities [6 October 2021]

Environment: Orgalim response to the consultation by the Platform on Sustainable Finance on EU taxonomy [5 October 2021]

Environment: Joint statement on the need for a transition period for the implementation of the Batteries Regulation [28 July 2021]