Open Letter: NGOs reaction to the Joint industry position paper regarding the waste framework directive database

The document is an open letter from 41 NGOs supporting the creation of an ECHA database for substances of very high concern (SVHCs) in products, as mandated by Article 9 of the revised Waste Framework Directive. The NGOs argue that this database is essential for a non-toxic circular economy, human health, and environmental protection, countering a position paper from 12 industry groups that sought to replace the database with alternative research and technology investments. The NGOs assert that industry already has a legal obligation under REACH to possess this information and that transparency is necessary for citizens' right to know, market surveillance, and the safety of waste handlers.

• Forty-one NGOs support the ECHA database of substances of very high concern in products mandated by Article 9 of the revised Waste Framework Directive, which entered into force in July 2018.
• Twelve industry groups have published a position paper requesting that ECHA reconsider the database in favor of alternative actions, including investment in research, analytical/testing methods, and the development of recycling technologies.
• The NGOs argue that the database is critical for several reasons: enabling citizens' right to know, allowing companies to manage chemical risks and transition to safer alternatives, assisting public authorities in market surveillance and law enforcement, and protecting the occupational health of recyclers and waste handlers.
• The NGOs contend that industry's claim of a new burden is unjustified because companies have been legally required to collect and disseminate information on substances of very high concern for over 10 years under the EU REACH regulation.

APA

ClientEarth (2018). Open Letter: NGOs reaction to the Joint industry position paper regarding the waste framework directive database. https://www.clientearth.org/media/s02dnqco/open-letter-ngos-reaction-to-the-joint-industry-position-paper-regarding-the-waste-framework-directive-database-coll-en.pdf

Chicago

ClientEarth. Open Letter: NGOs reaction to the Joint industry position paper regarding the waste framework directive database. 2018. https://www.clientearth.org/media/s02dnqco/open-letter-ngos-reaction-to-the-joint-industry-position-paper-regarding-the-waste-framework-directive-database-coll-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Open Letter: NGOs reaction to the Joint industry position paper regarding the waste framework directive database |date=December 2018 |url=https://www.clientearth.org/media/s02dnqco/open-letter-ngos-reaction-to-the-joint-industry-position-paper-regarding-the-waste-framework-directive-database-coll-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2018open, author = {{ClientEarth}}, title = {{Open Letter: NGOs reaction to the Joint industry position paper regarding the waste framework directive database}}, publisher = {ClientEarth}, year = {2018}, month = dec, url = {https://www.clientearth.org/media/s02dnqco/open-letter-ngos-reaction-to-the-joint-industry-position-paper-regarding-the-waste-framework-directive-database-coll-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }