Position paper | English | Deutsch | Français | Italiano

Recommendations by an EU-wide cross-industry initiative for better regulation in chemicals management

Better regulation in chemicals management requires identification, implementation and enforcement of the most effective risk management option, tailored to tackle a specific risk. Please find the document below in English, German, French and Italian. 


CII feedback to the commission inception impact assessments ahead of the revision of the CLP regulation

The CII welcomes the Commission Inception Impact Assessments for the revision of the CLP Regulation. In this context, the CII does not recommend the introduction of the possibility to set harmonised limit values by CLP. The CII urges the Commission and Member States to assess whether such limit values set under the CLP would in any way pre-empt the necessary considerations in risk management. This is essential to enable tailored and efficient protection of workers from chemical risks, while maintaining workplaces and the competitiveness of European industries.


Joint SMEUnited and CII views on DGs ENV-GROW paper on REACH Restriction and OSH OELVs

SMEUnited and the CII welcome the Commission’s initiative to clarify the REACH-OSH interface and consider that transparent procedures and criteria should be used when selecting the most appropriate regulatory options. We welcome the DGs ENV-GROW’s thought-starter to promote a decision tree that would clarify the interface and optimise worker protection.


CII recommendations regarding the EU Strategic Framework on Health and Safety at Work (2021-2027)

The CII fully supports a strong EU framework for Occupational Health and Safety (OSH) that strives for a consistent improvement of the health and safety of workers across Europe. To ensure an ever-stronger OSH framework and its implementation in the EU, the CII recommends clarifying of the interface between REACH and OSH legislations, as well as improving the predictability and consistency of RMOAs.


CII response to ECHA RAC/SEAC opinion on an Annex XV restriction dossier for N,N Dimethylformamide (DMF)

The CII considers the restriction proposal applied to DMF is not the appropriate policy instrument to manage risks posed by exposure to chemicals in the work environment. In this context, the CII considers that the REACH-OSH interface should be clarified with priority.


CII contribution to the consultation regarding the 4th revision of the Carcinogens and Mutagens Directive 2004/37/EC

The CII welcomes the Commission’s proposal for a revision of the Carcinogens and Mutagens Directive (CMD) and would like to express its support to the further setting of occupational exposure limit values (OELVs) for substances presenting a risk in the workplace specifically.


Towards a more effective and consistent RMOA process to support the ambitions of the European Green Deal

The CII encourages an open and inclusive discussion between authorities and stakeholders on how to further improve Risk Management Option Analyses (RMOAs).


6 Recommendations for better RMOAs


CII recommendations for a more effective and consistent RMOA process

The present paper analyses the status of what has already been achieved by means of RMOAs and identifies areas where, after several years of positive experiences with RMOAs, there may be opportunities for enhancing their consistency and effectiveness. This would make regulatory measures more efficient and targeted.


CII feedback to European Commission Chemical Strategy for Sustainability

The CII encourages an open and inclusive discussion between authorities and stakeholders on how to further improve the selection of Risk Management Options (RMOs)