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Position Papers

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)

Posted on by CETSEU
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)

Posted on by CETSEU
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)

Posted on by CETSEU
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)

Posted on by CETSEU
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)

Posted on by CETSEU
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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