The European Environmental Bureau (EEB) and CHEMTrust presents the comments on the proposal to establish a Subgroup on Test Methods within CARACAL, dated September 6, 2024. We acknowledge the importance of developing adequate and validated test methods to ensure effective implementation of the REACH and CLP regulations, addressing the current gaps and delays that hinder the timely regulation of harmful chemical substances. (CARACAL 52, Joint REACH – CLP session, AP 4.a 6 September).