PU Europe, the European Federation of PUR/PIR rigid polyurethane insulation manufacturers, appreciates the opportunity to contribute to the inception impact assessments for the revision of both the REACH and the CLP Regulations. Our industry acknowledges the non-disputable role that REACH and CLP Regulations have played over the last decades and stands ready to help achieving a higher level of protection of citizens and the environment against hazardous chemicals.
However it is necessary to highlight that the European Green Deal in not only flanked by a Chemicals Strategy for Sustainability for a toxic-free environment, but also by the Renovation Wave Strategy. As part of the ambitious objectives on many fronts which have been set by the European Commission, the Climate Neutrality by 2050 is for sure the most critical one. A number of products, like the ones manufactured by our members, are urgently needed to curb GHG emissions from the building sector even if certain of those products rely on substances exhibiting hazardous characters. The mere presence of chemicals labelled as hazardous does not translate into risks for workers and/or end-users of those articles. A risk management approach is central to protecting health & environment while meeting other societal challenges.