To whom it might concern
In view of a policy framework, and especially regarding circular economy, a holistic approach it is crucial.
It is beyond controversy that minimizing climate change, ozone depletion, acidification, eutrophication, resource use and others are important contributions on the way to circular economy. In addition to that the impacts from chemicals at various stages of products manufacture, use and end-of-life for human health and the environment should not be neglected or underestimated.
In this regard we want to indicate that the model for characterizing human and ecotoxicological impacts of chemicals used these days for life cycle assessment (PEF and OEF) isn’t mature, and that the proposed weighting scores for the EF underestimate the contributions of chemicals at an alarming level.
(Find the justification at the attached file)
Christian Kornherr - Susanne Stark
Representing the Austrian Competent Body for the EU Ecolabel
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