The Circular Economy (CE) strategy and its related measures, such as the recent European Commission communication on the interface between chemicals, products and waste, is an important initiative, for both society and industry. Its ultimate aim is the sustainable use of resources through the entire product lifecycle, which is an aim the above signatory industries fully support.
For the reasons explained in this paper, the signatory industries strongly believe that the database will not achieve its intended objectives to support the CE. In addition, the ECHA proposal will not be workable for industry nor enforceable by authorities. Instead we call for an approach that allows different, flexible and effective CE solutions tailored to the specific circumstances of each industry sector, depending on the complexity and durability of their products.
These industries represent the majority of EU article manufacturers, assemblers, importers and distributors, with wide variety in size, use base and complexity of processes and products. Due to this wide variety and diversity a tailored approach is required not only for technical solutions but also regarding legislative measures.
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