Document evEX1d0yD1Mwm9xBYY8KZxMNg

FPPEEU A sector groupof Cefic DirectorofRisk Management a po-- Telakkakatu 6 sorts Re: Proposing a smoother process for stakeholder contribution to the U-PFAS restriction proposal rcs adorrneRaersoivnassion ling |Chairofthe Socio-Economic Analysis Committee oo ER reT nter reR eins ie wlagtv Ste YSo hEetRoSs PSegep.sHRPTtn ening ne Commtuer cement hatsaw amar he restoaA--E Shou ih rtetheyave ng oy fle and crnVoth roc. We believe that stakeholders' participation will help to ensure a robust and sound ECHA opinion. Therefore, we kindly ask you to consider the challenges reported, i as well as some proposed measures to + DCoimmtitteoens ooff sCocmamimtpeeidpocemeasns,rTowhinsge0ss0menhatleonfgtihneg.dSoommeteismestoebmeendicveusdeocdumbeyntthse cWonth rf pons ofthe CAomite, av vA alle ane dS oy before sPh Oct.TExEpertAove ites onda posting Sameer abs ess bth Sadud babel (regular and occasional) at least one week before i the Committees' meeting, in particular the draft TRTTR EUTransparencyRegister n* 64879142323-90 + Minutes of the Committee meetings. Visibility of the main discussions and outcomes is essential to alow stakeholders to better understand and participate into the process and provide expertise on this complex file. Concrete updates about the proceedings communicated during meetings should be made available to al interested stakeholders. This would ensure equal access to information, even for those stakeholders that are not invited to specific meetings. Please consider the possibilty of drafting more detailed minutes describing key concepts and decisions proposed by the Committees ( Access to the Background Document (8D). The 80 is revised to incorporate new data including the information gathered during the consultation launched on the Restriction proposal. An early access to the BD revised versions will enable stakeholders to understand the development of the assessment of the uses, the remaining data gaps and to optimally prepare for the SEACdraft opinion consultation. Please consider the preliminary publication of revised versions of the BD, Access to the Responsteos the Comments to the Consultation (RCOM). The dossier subiters and the rapporteurs will address the comments submitted by the stakeholders in the consultation launched on the restriction in the RCOM. We assume that the contributions dealing vith the specific uses discussed in the plenary meetings are prioritised in such assessment. Publishing the RCOM on the specific uses before they are discussed in the Committees' meetings will allow interested parties to better contribute to the Committees' discussions and will help them to prepare in advance their contribution to the SEAC draft opinion consultation. Please consider publishing the RCOM specific to the uses to be discussed in the plenary in advance of the Committee discussions. + Information on Alternatives. Different documents of the restriction proposal include information on alternatives, such as the restriction report, annexes, and the revised versions of the B. However, there is no clarity on the criteria used to assess the acceptability of the alternatives for the different uses by the Committees. A detailed explanation of the elements considered when assessing alternatives will allow the stakeholders to provide useful data and understand the proposals made on the different uses. Please consider providing information on the criteria used to assess alternatives, Regular public updates. Access to updated information is going to be crucial to allow interested parties to continue contributing to the process. We very much appreciate the current intitives taken by ECHA on this regard, such as the podcast episodes. Other channels or forms of updates could be considered to ensure the widest access possible o the information. Please consider providing additional updates on the Restriction proposal Including info sessions with Q&Aor a standing column on PFAS in the ECHA newsletter. + Onboarding sessions for new stakeholders. The PFAS proposed restriction has attracted a significant number of new stakeholders. They may not be familar with the practicaites entailed in the rol, such a5 access to the updated documents through the relevant tools (Circa / Interact), or even the nature of the documents that are shared. Please consider practical onboarding session for the newcomers. 2 .