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BeST publishes comments on Essential Use Concept

On 11 March, a workshop on the Essential Use Criteria (EUC) took place. The EUC, which was first announced in the frame of the EU’s Chemicals Strategy for Sustainability (CSS), will look at the essentiality of the end-use of the substance intended as a technical function and will allegedly be used for both generic and specific approaches to chemicals’ risk management.


Considering the discussion during the workshop and the documents disclosed to stakeholders, BeST has prepared a position paper stressing the essential role of the Safe Use Concept in the frame of the EUC.

BeST has also raised concerns on:

  • The natural vagueness and subjectivity of criteria determining essentiality.

  • The neat departure of the EUC concept from the already-implemented risk-based regulatory approach.

  • The unintended consequences of decoupling substances from their contribution to the performance of the end product.

  • BeST argues that where the use of a substance is proven to be safe, the essentiality assessment should be irrelevant.


To access BeST’s position paper, download the pdf file below.


BeST Comments Essential Use Concept
.pdf
Download PDF • 308KB

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