ANEC contribution to the IIA Roadmap on the Revision of EU rules on food contact materials

The IIA roadmap talks about "a generic approach to the assessment and management of those substances with the most hazardous properties". This could mean to use the hazard classes just as an instrument for priority setting of assessments. This is highly questionable. We regret this misinterprets the generic approach to risk management outlined in the EU Chemicals Strategy, which means it as a ban of CMRs and other harmful chemicals in a generic fashion based on the CLP hazard classification. The strategy states “the generic approach to risk management becomes the default option, in particular as regards their use in consumer products".

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