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The Canadian Climate Institute supports the Office of the Superintendent of Financial Institutions' (OSFI) draft Standardized Climate Scenario Exercise (SCSE) but argues it is currently oversimplified. The Institute recommends that OSFI explicitly disclose limitations regarding the lack of regional data and the omission of clean energy opportunities. It specifically warns that the SCSE confuses 'exposure' with 'risk' in its physical and real estate modules, failing to account for asset vulnerability and comprehensive climate policy. To increase practical value, the Institute suggests piloting risk assessments for a small number of highly material risks, such as flooding, rather than broad hazard exposure mapping.

The EEB and ClientEarth submission to ECHA argues for a comprehensive restriction on intentionally added microplastics, warning that ECHA may prematurely narrow the scope of restrictions through unjustified derogations. The authors advocate for treating microplastics as non-threshold substances, similar to vPvB or PBT substances, due to their persistence and ability to bioaccumulate. They highlight the role of microplastics in transporting persistent organic pollutants (POPs) and leaching endocrine-disrupting additives into the environment and human body. The submission supports a broad definition of microplastics that includes liquid polymers and compostable bioplastics, and emphasizes the need to consider the high exposure risks associated with nanoplastics.