CECE has welcomed the European Commission’s efforts to reduce administrative burdens in environmental legislation and has outlined several priority requests to ensure effective and balanced implementation.
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SCIP Database – CECE calls for eliminating the database under the Waste Framework Directive, arguing that it duplicates REACH obligations and creates confusion. Instead, reliance should be placed on REACH requirements or integration into the Digital Product Passport (DPP).
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Ecodesign for Sustainable Products Regulation (ESPR) – The industry urges smooth implementation by aligning timelines with related laws (e.g., PPWR, REACH), excluding packaging from scope, recognizing REACH as the main chemical framework, reviewing the DPP process, and reducing unnecessary third-party conformity checks.
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Substances of Concern (SoC) – CECE asks for a more targeted approach, warning that the current broad definition is unmanageable and may undermine circularity goals by restricting substances essential for safety, longevity, or sustainability.
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F-Gas Regulation – CECE supports maintaining fluorinated gases under the existing framework and excluding them from broader PFAS restrictions to provide legal clarity and secure long-term investments.
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PFAS restrictions under REACH – Instead of blanket bans, CECE recommends a risk-based approach focused on controlling hazardous emissions while recognizing essential uses where alternatives are not yet viable.
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Packaging and Packaging Waste Regulation (PPWR) – The industry requests harmonized, simplified rules across Member States, including the use of English documentation and reduced reporting frequency.
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Battery Regulation – CECE proposes easing due diligence and conformity burdens by aligning with the Corporate Sustainability Due Diligence Directive and allowing self-assessment for certain categories of battery-components, simplifying labelling rules, and removing unnecessary requirements like batch numbers and redundant documentation.
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Extended Producer Responsibility (EPR) – CECE calls for harmonized application across the EU to avoid fragmented national rules that increase costs and complicate compliance with ESG goals.