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The new Article 9 of the EU Waste Framework Directive, adopted in 2018, gives to ECHA the task of creating a database to gather information on the substances of very high concern (SVHC) that are present in the products available on the EU market.
The obligation to know whether the products one industry places on the EU market contain SVHC, and the obligation to provide this information to the supply chain, and to consumers, is however not new; industries have had to comply with it for 10 years, and have consistently failed to do so. This is precisely the failure that motivated the EU legislator to create an extra incentive.
12 industries released in October 2018 a position paper calling ECHA to reconsider the creation of the database - even though its creation is already required by law, and would actively support the creation of a safe circular economy.
This letter is the joint reaction of 41 NGOs to the industry position paper. It calls on ECHA to remain determined in setting a meaningful and useful database, containing the information needed to achieve the objectives set by the EU legislators and to achieve a non-toxic circular economy.