EEB, HEAL and ClientEarth comment on the SEAC draft Opinion on single-use baby diapers restriction

The EEB, HEAL and ClientEarth welcome the opportunity to comment on the draft opinion of SEAC related to the proposal to restrict a number of substances of concern present in singleuse baby diapers.

As a preliminary observation, we regret that the joint comments that we submitted in the context of the development of the RAC opinion - the latter is referred to a number of times in the SEAC opinion - have not been considered properly. SEAC should develop its own opinion independently of RAC’s opinion, but since it mentions the latter as an important factor in the outcome of its own opinion, we feel the necessity to stress this important shortcoming. In particular, our previous comments have highlighted in detail how the vulnerability of the targeted public of this restriction should be an important guiding aspect in its development and how it justifies a precautionary approach in the use of existing data related to exposure as well as uncertainties.

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