EU Waste Framework DirectivJoint Industry Appeal to EU: Make Substances of Concern Rules Clear, Consistent and Implementable
“𝐀 𝐡𝐚𝐫𝐦𝐨𝐧𝐢𝐬𝐞𝐝 𝐚𝐧𝐝 𝐰𝐨𝐫𝐤𝐚𝐛𝐥𝐞 𝐚𝐩𝐩𝐫𝐨𝐚𝐜𝐡 𝐭𝐨 𝐒𝐮𝐛𝐬𝐭𝐚𝐧𝐜𝐞𝐬 𝐨𝐟 𝐂𝐨𝐧𝐜𝐞𝐫𝐧 (𝐒𝐨𝐂) 𝐢𝐬 𝐞𝐬𝐬𝐞𝐧𝐭𝐢𝐚𝐥 𝐭𝐨 𝐞𝐧𝐬𝐮𝐫𝐞 𝐭𝐡𝐚𝐭 𝐄𝐮𝐫𝐨𝐩𝐞’𝐬 𝐞𝐧𝐯𝐢𝐫𝐨𝐧𝐦𝐞𝐧𝐭𝐚𝐥 𝐨𝐛𝐣𝐞𝐜𝐭𝐢𝐯𝐞𝐬 𝐜𝐚𝐧 𝐛𝐞 𝐚𝐜𝐡𝐢𝐞𝐯𝐞𝐝 𝐰𝐡𝐢𝐥𝐞 𝐬𝐚𝐟𝐞𝐠𝐮𝐚𝐫𝐝𝐢𝐧𝐠 𝐢𝐧𝐝𝐮𝐬𝐭𝐫𝐢𝐚𝐥 𝐜𝐨𝐦𝐩𝐞𝐭𝐢𝐭𝐢𝐯𝐞𝐧𝐞𝐬𝐬.”
In an initiative led by APPLiA and Orgalim, a broad coalition of European industries addressed a joint letter to the European Commission, raising concerns about the current design of SoC provisions under the Ecodesign for Sustainable Products Regulation (ESPR), the Corporate Sustainability Reporting Directive (CSRD) and other legislation.
The message is clear: inconsistent definitions, duplicate information requirements and vague criteria create legal uncertainty and unnecessary burdens, without making legislation more effective.
What is needed is a targeted, feasible and consistent approach, building on existing frameworks such as REACH, to ensure rules are both implementable and enforceable across the SingleMarket.
This balanced approach will make the EU regulatory framework more effective and workable, supporting Europe’s circular economy ambitions while strengthening sustainability outcomes and Europe’s competitiveness.