Joint industry call for a harmonised and workable framework on Substances of Concern (SoC)

• CECE and a coalition of European industries have called for a coherent and practical approach to Substances of Concern (SoC) to support environmental goals and industry competitiveness.

• The joint letter to the European Commission highlights concerns with the current design of SoC provisions under ESPR, CSRD, and related legislation.

• The signatories emphasize the need for a proportionate, workable, and consistent framework to avoid legal uncertainty and administrative burdens.

• The letter advocates for a harmonised, targeted, and risk-based approach to substances in products and avoiding duplicate information requirements.

• CECE supports a "One list – One Declaration" principle for hazardous chemicals and stresses the importance of a uniform and well-defined concept for information requirements developed under REACH.

A coherent and practical approach to Substances of Concern (SoC) is crucial to enable Europe to reach its environmental goals while preserving the competitiveness of European industry.

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In a joint letter to the European Commission, CECE – together with a broad coalition of European industries – raised strong concerns and provided recommendations on the current design of SoC provisions, in particular under the Ecodesign for Sustainable Products Regulation (ESPR), the Corporate Sustainability Reporting Directive (CSRD), and related legislation.

The signatories underline the need for a proportionate, workable, and consistent framework. At present, overlapping definitions, duplicative reporting obligations, and unclear criteria risk generating legal uncertainty and disproportionate administrative burdens for companies across the Single Market.

While it is essential to regulate hazardous chemicals, we do not believe the SOCs are the most effective policy mechanism for achieving this. It is impractical (if not impossible) to manage such a broad and vague list of chemicals. For these reasons, the letter calls for:

• Ensuring a harmonised, targeted, and risk-based approach to substances in products.

• Avoiding duplicate information requirements already covered by SVHCs in REACH and other regulations.

• Adopting a “One list – One Declaration” principle for hazardous chemicals.

CECE stresses that a uniform and well-defined concept for information requirements on substances subject to regulation – developed under REACH and with structured stakeholder input – is the right way forward.

Such a balanced and harmonised approach would improve the effectiveness and predictability of EU legislation, ensuring it delivers on Europe’s circular economy and sustainability ambitions while supporting the competitiveness and innovation capacity of European manufacturers.