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Policy papers 10 September 2025

Joint industry call for a harmonised and workable framework on substances of concern (SoC)

A harmonised and workable approach to Substances of Concern (SoC) is essential to ensure that Europe’s environmental objectives can be met while safeguarding industrial competitiveness.

In a joint letter sent to the European Commission, a broad coalition of European industries, including APPLiA, expressed significant concerns and recommendations on the current design of the SoC provisions, in particular under the Ecodesign for Sustainable Products Regulation (ESPR), the Corporate Sustainability Reporting Directive (CSRD) and other legislation.

The letter highlights the need for a targeted, feasible and consistent approach. Today, inconsistent definitions, duplicate information requirements and vague criteria risk creating legal uncertainty and unnecessary burdens for companies across the Single Market. Instead, what is needed is a uniform concept for information requirements on substances that require regulation, implemented under REACH and supported by stakeholder involvement.

As outlined in the letter, this balanced approach would make the EU regulatory framework more effective and workable to support Europe’s circular economy ambitions, while strengthening both sustainability outcomes and the competitiveness of European companies.

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