Document bO04Z35x6DrR801R51dNJxwZZ

| ---- H&M Group's suggestions to secure an ambitious revision of REACH Regulation March 2023 H&M Group is calling on the EU authorities to conducat prompt and ambitious revision of the REACH Regulation. Enabling substitution of hazardous substances is essential to guaranteesafer and more sustainable productsA. robust legal framework is necessary for a systemic change and long-term action, backing industry leaders' investments. in proactive chemicals management. Cprhienmtiincga.lsH&arMe Gerssoeunptiiaslwotorkpirnogcetsoseenssuurseedthtaot amllakoeurgparromdeuncttss,asruecshafaestwharsohuignhgo,utdytehiengfu,llalnifde ccyhcelmei.cWale rweesrtreicetairolnyspiinon1e9e9r5s,iannodurrienmdauisntrcyoimnmcihtetmeidcatlosomuarnapguermpeosnet,ofhalveiandginigsstuheed ionudrusfitrrsyt stuocwharadsstchheeAmpicpaalrleylsaanfedpFrooodtuwcteiaornIanntedrnarattiicolnesa.l WReSLhMaavenacgo-efmoeunntde(dAiFnIdRuMs)trGyr-loeuapdianngdnetthweoZrekrso mDaitsecrhiaarlgse aonfdHgarzoaurpdsouosf Cchheemmiiccaallss s(uZcDhHCa)s PPrVoCgr(ainmm1e9,99a)s, wPeFlAlSa(s20s1ub3s)tiatnudtedsoplrvoebnlte-mbaatsiecd polyurethane (2020). The toxicological research on hazardous chemicals continues to evolve rapidly. We are aware that we must keep up with this development and speed up chemical substitution efforts to ensure safetyof ourproducts.That is why we support the EU Commission's commitment made in the EU Chemicals Strategy (CSS) to reduce consumer exposure to the most hazardous chemicals While there is no doubt that the REACH Regulation focuses on chemical safety, we cannot ignore its impactsonproduct sustainability. The rapid advancementoftoxicological research means that certain chemicals, which are perceived today (due to lack of information) as safe enough to be used in virgin materials, may constrain recyclingof those same materialsa few years from now. We have a commitment 2030, which will require dteoteanilseudreuntdheartsatlalnodiunrgparnodduccotnstraorleofdelseiggancyedchfeomriccailrcsu.larity by " RE " We will not be able to achieve oursafety and sustainability goals withouta strong EU chemicals' policy. An ambitious REACH revision -thatis,such that reflects the commitmmaedenintthse CSS. is urgently needed to incentivise the whole industry to innovate and change. It is also needed toensurepredictability. Weare callionng the EU Commission to adanoambpititous revision of REACH Regulation as soon as possible, as we stated in December 2022 through a common letter co-signed with ChemSecand 21 other frontrunners: in chemicals management. We Kindly ask the EU Parliament, EU Council and ECHA to support the EU Commission in realising the commitments made in the CSS. "bTahseeadmabpiptrioouaschEaUncdhecmhiecmailcsalltarwansshpoaurledncreyl.y on two components of utmost importance: hazard- * tps chemsec.org/a-compan. request for an ambitious evison-of reach/ Integrate the hazard-basedapproach iWnecrebaelsiienvgelythbaatsethde opnrotcheesisr oifntrreisntsircicthianzgartdhse, mroasttherhatzhaarndoouns sthuebisrtaenxcpeossusrheoul(drisbke) estimates. While a risk of a given substance must be regularly reassessed, a hazard-based approach will enable us to achieve lasting compliance, thus making our industry future-proof. A hazard-based approach is also better from a safety perspective, and necessary to control legacy chemicals in recycled materials. In line with this view, we support the proposal made by the EU Commission in the CSS to extend the generic approach to risk management (GRA) to non-essential uses of substances in the new CLP hazard classes, such as endocrine disruptors. We would like to emphasise that the GRA restriction process should remain open for the industry to participate. Textile industry has years of technical experience in substituting the most harmful chemicals. It should be consulted to ensure that the GRA restrictions consider available technical analysis and methods, and the relevance of restricted substances for our industry sector. We. believe that the 2018 REACH restriction of carcinogenic and mutagenic substances in textile articles can serve as a blueprint ofa good application of the extended GRA approach. This restriction process was effective in reducing a serious health hazard, at the same time ensuring the adequate level of industry's participation. While tracing and phasing out hazardous chemicals, the textile industry faces a major hurdie: insufficient information on chemical products from chemical suppliers. Currently, the primary information carrier about chemical products, the Safety Data Sheet, does not provide textile brands with enough information on the content of chemical formulations and hazardous properties, This is the case predominantlyfor substances which do not have a harmonised hazard classification under the EU regulation on the Classification, Labellingand Packagingof substances and mixtures (CLP). We have avery limited access to the hazard propertiesofthese substances, as the existing REACH obligation to provide self-classifications (information based on chemical producers' own research) is not well-enforced. Moreover, information is lacking also on classified substances which do not exceed the limit of 0.19 w/w in chemical mixtures (the minimum threshold level for chemical products' labelling required under CLP). "This situation leaves us with scarce information about most ingredients in chemical products, hindering our chemical traceability efforts and causing therisk of regrettable substitutions. We need a new, smart modelof transparency that will enhance information flow from the chemicals supply chain. We believe that the access to information should be improved for unclassified substances, as well as substances present at small concentrations. This is, firstlya, prerequisite for proactive chemical substitutions necessary to ensurae safe and circular fashion - according to the standards of today and tomorrow. As an example, having a better chemical transparency would have made our proactive substitution of PFAS in 2013 a `much easier process. Today, while the PFAS restriction under REACH is only starting, many of these substances still do not have a harmonised CLP classification. The lack of information on chemicals will hinder any proactive chemical substitutions in the future. Secondly, we need improved chemical transparency to ensure legal compliance with the large gbreovuiptalrefsotrriucstitoonscocmopmliyngwiutnhdethreRrEeAqCuHi.reWmeentarseoenxpseucbtsitnagnctehsatocfhceomniccearlnturnadnespratrheencEycow-idllesailgsno Regulation (ESPR) - as chemical substances regulated for sustainability reasons, not chemical safety reasons, may not have a CLP classification. Some promising options and tools to improve chemical transparency have been proposed during tFuhlelAMSaKteRrEiaAlCHDepcrloajreactito'n,in wdhatiachprHov&iMsiGonrovuipa ttoheokDipgairtt,alanPdrowdhuiccthPfaesastpuorretdoErnShCaInPcdeadtaDbaatsae.SheWete, are calling on the EU Commission to perform a systemic impact assessment to evaluate how the various initiatives can contribute to the transparency and traceability vision. ContactpersonsforGlobal Public Affairs: Cantactpesonfor EU Public Affairs: |. hin.com - HEMGrowp fff COS WEEKDAY MONKL AMHOME etinSis ARKET 40ND HbuseinnFeMsnsiedeasist&Mooafeur rfiaABsa(hnpduibq)uoalwinatsyfaotuthnedbeedsintSwperdeianscuiesntna1i9n4a7blaenwday.is cInuaotdedd ionttNoiiHosSdnMq Stthoecgkrlooulpn,incHluSdeMs tvhisbtrhamngdrsoCuOpS,coMmon, Weekday, & Othe Stories,H&MHOME and ARKET as wel5 Aloud. For further information 2 https: June asireach eu/wp:-content/uploads/2023/01/ASREACH Traceabiity-WS report 2023.01pdf