Document 5bq61968wjdzGgoEy0Br6wwV8
EUROPEAN COMMISSION
Ref. Ares(2022)8256579 - 29/11/2022
DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP
AND SMES
Ecosystems I: Chemicals, Food, Retail F.2 - Bioeconomy, Chemicals & Cosmetics
Brussels
GROW.F.2/
MINUTES OF A MEETING WITH BAYER AG
Subject: Minutes of a meeting with Bayer AG on CSS
Date and time: 26/07/2022; 11.00 - 12.00
Participants: (GROW/F),
, (GROW/F1),
(Bayer AG); Kristin Schreiber (GROW/F2)
Discussion topics: CLP and REACH revisions
Concerning the CLP revision, Bayer AG expressed concerns about the introduction of new hazard classes under CLP and their impacts on downstream legislation, in particular pesticides and biocides. Bayer AG expects market reductions due to this introduction, mentioning that investment predictability is key. For the endocrine disruptor hazard class, Bayer AG mentioned the importance of aligning the new criteria under CLP with the existing ones under pesticides and biocides. Regarding persistent, mobile and toxic substances (PMTs), Bayer AG mentioned the importance of not only considering the KOC-factor as classification criteria, but of taking into account also other factors and data, and of adopting a weight of evidence approach. Bayer AG also enquired about the timing and procedure of the CLP revision.
Regarding the REACH revision, Bayer AG enquired about the implementation of the
essential use concept under REACH, mentioning that it sees difficulties in defining
essential uses. Bayer AG also enquired about the upcoming group restriction of PFAS, which would concern many of its products, and expressed concerns about a tout court ban. It also expressed concerns about the chemicals' export ban mentioned in the CSS,
since it would not be justified and lead to a change of production sites from Europe
elsewhere.
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