On Friday 11th January, the European Commission launched a Public Consultation on the update to the Classification, Labelling and Packaging of chemical substances and mixtures (CLP) Annex.
This is the regular update of substances that updates the RAC’s opinions. This is the 14th update. This is the first time the 4-week public consultation has been used for CLP Substance Annex updates.
https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2019-141469_en
The public consultation runs until 8th February.
The feedback can then be considered by the Member State Committee when they vote on 14th February.
This is a welcome development. It provides an opportunity to raise relevant (Better Regulation) issues that may have escaped the attention of those who have considered the matter before.
It is a final check before final decisions are taken. After all, there may be important vital issues – scientific, legal, economic – that officials from the Member States, Commission, Cabinet, and Agency, have overlooked.
It is unlikely that the Member State or Commission officials will encounter anything new. Already, most, if not all views, will have been brought to their attention.
As Cass Sunstein observes, when dealing with the US experience of cost benefit analysis, this review is unlikely to block action. Rather, it tends to land up adding to the case to support action. But, there will be cases, were taking action is not needed.