Documento riservato 1

Posted on by CETSEU
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Comments on the the PFAS restriction proposal: SEAC Draft Opinion on certain sectors and sub-uses – CETS, European Committee for Surface Treatment (deadline 2026/05/25)

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Summary: This comment refers to the latest ECHA call for information concerning the SEAC Draft Opinion on the PFAS restriction proposal, with particular regard to certain sectors and sub-uses. The document was developed within the CETS Board with the aim of highlighting and safeguarding key sector-specific considerations related to the use of PFAS in the surface treatment industry. It provi...
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Comments on the PFAS restriction proposal – Zentralverband Oberflächentechnik e.V., Germany (15/11/2023)

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Summary: This comment relates to the proposal for the restriction of PFASs submitted to ECHA on 7 February.The restriction proposal aims to restrict the production, use and placing on the market of PFAS inthe future. In terms of sustainable chemicals regulation, substances that pose unmanageable risks due to theirproperties and use profile should be regulated based on scientific assessments...
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Authorisation via end products and sectors – an impact assessment (26/1/2023)

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Summary: Anyone who has been following the events surrounding the authorisation of chromium trioxide under the REACH Regulation must realise that the discussion about applications for authorisation in the surface sector has become difficult to understand. Especially the so-called upstream authorisations of large consortia are facing altered requirements compared to the beginning of the process...
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The important contribution of electroplating for completing the circular economy (26/1/2023)

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Summary: Chrome-plated plastic components are an essential element for manufacturing long-lasting, sustainable and circular products. However, current regulatory restrictions under REACh are making this increasingly difficult. Key advantages over alternative technologies are being overlooked. The CETS therefore advocates that applications for the authorisation of chromium trioxide be accepted ...
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Intermediate concept within the framework of the European Chemicals Legislation – applicable rulings by the European Court of Justice (ECJ) have to implemented (25/7/2022)

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Summary: According to the REACh Regulation, the obligation for authorisation does not apply to intermediates. In this context, a clear definition is provided under which conditions a substance is to be classified as an intermediate. The European Chemicals Agency (ECHA) in 2010 presented a Guidance on Intermediates, which, according to an ECJ ruling in 2017, does not correspond with the aforeme...
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CETS calls for coordinated participation in the SEAC consultation on the Cr(VI) restriction (updated 2026.06.17)

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A decisive moment for the future regulatory framework of surface treatment in Europe The European regulatory process regarding the restriction of certain substances containing chromium(VI) has entered a crucial phase. The consultation on the SEAC draft opinion will open tomorrow, June 17, 2026, and will remain open for 60 days, until August 17, 2026. This phase represents an important opportun...
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REACH needs evidence of impact, not only procedural figures

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Europe needs measurable regulatory impact, not simply more administrative workload. The ECHA report on the implementation of REACH and CLP in 2026 describes a highly active regulatory system. For the period 2021 to 2025, the report refers, among other figures, to 18,911 initial registrations, 45,189 dossier updates, 1,528 compliance checks, 161 substance evaluations, 6,745 additional informati...
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REACH needs evidence of impact, not only procedural figures

Posted on by CETSEU
Europe needs measurable regulatory impact, not simply more administrative workload. The ECHA report on the implementation of REACH and CLP in 2026 describes a highly active regulatory system. For the period 2021 to 2025, the report refers, among other figures, to 18,911 initial registrations, 45,189 dossier updates, 1,528 compliance checks, 161 substance evaluations, 6,745 additional informat...
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CETS Meeting: From participation to influence

Posted on by CETSEU
A new strategic chapter for European surface treatment representation On 30 March 2026, CETS held a meeting with representatives of its member associations to discuss the future strategic model of the organisation and the operational steps needed to strengthen its European representation. The meeting marked an important moment of alignment, confirming the need to move from occasional participa...
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