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JBCE's Environment & Energy Committee submitted its views during the call for evidence on ECHA’s investigation report on PVC and its additives

06/01/2023

On 6th January, JBCE submitted its views during the call for evidence on ECHA’s investigation report on PVC and its additives.

JBCE highlighted the following points on our views:

  • Chemicals should be used properly and to ensure a high level of product safety, reliability and functionality. At the same time, the use of chemicals in products should not run counter the protection of human health and the environment.
  • Alternatives should be carefully evaluated to avoid “regrettable substitutes”. Special attention should be paid to the final products: the availability of alternative materials does not mean that real substitutes for final products are available.
  • Sufficient transition period for each product groups should be considered since long and complex supply chains are involved. Special attention should be paid for the products with long model lifetime (mostly medical devices and analytical devices) in order to avoid the shortage of these devices on EU market.
  • Harmonisation of substance restriction with Harmonised Standards for product-specific legislations are necessary. 

You can download our position below.

For more information please contact:

Tetsusaburo Miura, Policy Manager, Environment & Energy

(This email address is being protected from spambots. You need JavaScript enabled to view it.)