Your Honor, what were we talking about, again?
Just a quick note regarding the need to be precise when presenting your concerns to ECHA. On April 4th this year, the EU’s General Court (Fifth Chamber) handed down it’s judgement in Case T‑108/17, involving the organization Client Earth as the applicant, the European Commission (EC) as the defendant and the European Chemical Agency (ECHA) as an intervener party. The details are many, but in essence the EC had authorized certain parties to reuse waste PVC (recyclate) to make new PVC articles. PVC articles often contain bis(2-ethylhexyl) phthalate (DEHP) as it makes the product more flexible (e.g., power cords and cabling); the authorization allowed up to 20% of DEHP to be present as an incidental chemical in recycled PVC articles. Client Earth had concerns that the decision process used to grant the authorization was not comprehensive and sought to reverse the authorization. After a very detailed review of the request, the Court decided that the request was unfounded for several reasons, and that the authorization will remain active as is.
Whichever side you’re on with this case, I suggest you read at least one of these judgements to get a sense of the depth of analysis that’s done to make a determination. There are many points addressed in the judgement and it’s clear that the Court takes these matters seriously. Be warned: this is not light reading, but it IS informative.
Here’s the link to the judgment. You can be sure that future cases will also be just as scrutinized to cover all aspects.
A View From the Geek Seats 