Comments to the presentation of essential use concept (AP4_1 CARACAL 47) - General comments

Comments to the presentation of essential use concept (AP4_1 CARACAL 47) 8 December 2022 Document sent to: GROW-CARACAL@ec.europa.eu, ENV-CARACAL@ec.europa.eu, and GROW- ENV-REACH-REVISION@ec.europa.eu General comments The proposed essential use concept is the right approach to increase the protection of people and the environment; ensure the rapid and efficient phase out of the most harmful chemi. [...] The EEB believes that the concept should not assess whether chemicals or everyday products are essential, but whether the use of chemicals of concern in consumer products is justified and acceptable for society. [...] In other words, the use of such hazardous chemicals in products, citizens are frequently exposed to, should only be possible when such chemical use is truly necessary for health and safety, critical for the well-functioning of the society and there are no safer alternatives available. [...] Critical for the functioning of society: However, we disagree with consultants on the statement that uses which are critical for the functioning of society includes running traditional and religious practices. [...] However, referring to ECHA’s definition of suitable alternative as those that are also economically feasible is not the best approach given the poor results of the ECHA’s opinions on the matter, as shown by the rulings on chrome trioxide authorisations.