Concerns about the Sixth Omnibus on chemicals

The document is a formal letter from ClientEarth and other civil society organisations to the European Commission expressing strong opposition to the Sixth Omnibus on chemicals. The authors argue that the proposal, which seeks to simplify requirements in the CLP, Cosmetic Products, and Fertilising Products Regulations, actually promotes deregulation and undermines EU competitiveness by creating regulatory instability. They specifically highlight 'severe cases of maladministration' regarding the proposed rollback of CLP Regulation formatting rules, claiming the Commission bypassed public consultation and lacked a proper evidence basis. The letter warns that these procedural flaws violate EU primary law and the Charter of Fundamental Rights, potentially leading to the legislation being annulled by EU courts.

• The proposed Sixth Omnibus on chemicals is characterised as a case of deregulation that undermines EU industry by eroding regulatory predictability and penalising companies that already invested in compliance with recent CLP Regulation improvements.
• The European Commission is accused of maladministration in preparing the proposal, specifically regarding the rollback of CLP Regulation formatting rules intended for 2027. The authors claim the Commission failed to conduct a public consultation, lacked an evidence-based decision-making process, and ignored the need for a proportionality assessment.
• The proposal is alleged to conflict with the EU Charter of Fundamental Rights, specifically Article 35 regarding human health protection and Article 37 regarding the improvement of environmental quality.
• The authors warn that structural procedural flaws make the proposal vulnerable to legal challenges from Member States, private operators, and civil society, which could result in the legislation being found invalid by EU courts.

APA

ClientEarth (2025). Concerns about the Sixth Omnibus on chemicals. https://www.clientearth.org/media/aupjcz42/letter-to-the-ec-chemicals-omnibus-fin.pdf

Chicago

ClientEarth. Concerns about the Sixth Omnibus on chemicals. 2025. https://www.clientearth.org/media/aupjcz42/letter-to-the-ec-chemicals-omnibus-fin.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Concerns about the Sixth Omnibus on chemicals |date=9 July 2025 |url=https://www.clientearth.org/media/aupjcz42/letter-to-the-ec-chemicals-omnibus-fin.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2025concerns, author = {{ClientEarth}}, title = {{Concerns about the Sixth Omnibus on chemicals}}, publisher = {ClientEarth}, year = {2025}, month = jul, url = {https://www.clientearth.org/media/aupjcz42/letter-to-the-ec-chemicals-omnibus-fin.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }