Document rxvebJp0xanz1jgynD8nq097a

EUROPEAN COMMISSION Directorate-General for Trade Brussels, TRADE/D1 REPLY FROM DG TRADE Interservice consultation launched by: DG ENV Reference: ISC/2020/05158 Title: Commission Communication on `Chemicals Strategy for Sustainability: Towards a Toxic-free Environment' Persons to contact in DG: Niall LAWLOR phone: 91394 Agreement X Favourable opinion subject to account being taken of the following comments Negative opinion Thank you for the opportunity to comment on this important communication. We very much appreciate the changes made since the previous version of this communication, in particular to section 3.5 covering international aspects. However, we still have serious concerns with regards to a number elements of the text and would like to propose a number of drafting suggestions and comments as in the attached documents (Annexes 1 and 2). Their objective is to address the risk of unintended consequences for EU's international trade, including reputational, in terms of the EU being seen as protectionist and generating concerns from our partners in the WTO context (affecting our credibility and our WTO reform agenda). As such they aim at: - rebalancing the shift towards more hazard-based vs risk-based approach; - introducing a reference to international standards, guides and methodologies and to ensuring the compatibility with the WTO rules where appropriate; - reinforcing the wording on the need to be more pro-active in all international fora (OECD, UNEP, Stockholm etc.) as regards ongoing work to develop standards; - stressing the need for thorough impact assessments of all legislative proposals that are listed in the Annex as to compensate the lack of impact assessment for this strategy (and in this context, to analyze the international dimension); - underlining that the resilience of supply chains is also achieved by defending a fair and undistorted trade and investment environment facilitating the diversification of sourcing. DG TRADE takes note that this communication announces the creation of a broad alliance in this sector whose strategic orientations are not detailed in the present Commission europenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGI - Tel. +32 22991111 communication. As a consequence and in line with similar request for other industrial alliances, DG TRADE considers that the governance of these alliance should ensure a high level of transparency when defining its strategic orientations DG TRADE shares also general comments in the context of the WTO Agreement on Technical Barriers to Trade (Annex 3) and request for further close involvement in process of drafting the text of this communication. 2