BPF Additive Suppliers Group Update - Aug 2017

Dear Group Members,
Please find the following update of recent aspects regarding Plastics Regulatory control which may be of interest to you. The summary list encompasses some key aspects raised within the recent period.

Titanium Dioxide TiO2 white pigment

Two meetings were held in June by the European Risk Assessment Committee (RAC) responsible for examining substance ‘hazard’ in line with the regulatory process of Classification, Labelling and Packaging (CLP). The RAC made proposal that this substance be re-classified from non-hazardous to Class 2 Carcinogen via Inhalation.

This currently remains a proposal and it is yet to be adopted or any obligations imposed by the European Commission.

The decision was based upon a limited set of laboratory data, which many do not believe fully replicates industrial practice. Many sectors of European industry wish to present evidence demonstrating safe use and lack of incidence prior to any formal decision of obligations by the EU Commission.

The plastics industry is a significant user of this substance and to enable support, the BPF have issued a short survey to enable collation of data relevant to this cause. A report will be prepared for use at UK and European levels of advocacy.

It is kindly asked, that should your products be reliant upon this substance, you take a short time to review and respond to the survey issued irrespective of supply format used. For any questions relating to this survey, please contact Matt Davies directly.

Turkish REACH

Turkey has confirmed its plans to introduce its national version of chemicals regulation referred to as KKDIK. Registration (Kayit), Evaluation (Degerlendirme), Authorisation (Izin) and Restriction (Kisitlama) of Chemicals (Kimyasallar).

This regulation aligns very closely to EU Reach. The regulation will come in to force 23rd December, 2017 with an initial deadline for pre-registrations 31st December, 2010. Rather than a staggered volume based priority, the regulation will be applicable to all substances greater than 1,000kg per annum, thus finding prompt equivalence to EU Reach.

UK Chemical Stakeholders Forum

July saw another meeting of the UK Chemical Stakeholders Forum organised by Defra. Therese Coffey, Under Secretary of State for the Environment, also attended. There was an extended discussion as to the future strategy of chemicals regulation post Brexit and whilst no final strategy was confirmed, the minister indicated good knowledge of current regulations and the importance of REACH compliance towards future European trade relations. Post EU departure, no formal regulatory procedure was
clarified, although the minister appeared eager to resolve any uncertainty quickly and find a path that offered a level of mutual equivalence and recognition between the UK and the EU. She also re-iterated that there was clear objective to ensure there was no loss of safety or detriment to consumers or the environment yet several options are currently being examined by a much bolstered team at Defra which has grown in size to undertake this project.

It was made clear that industry must continue to remain compliant with existing regulations independent of current regional market focus and that obligations to Reach Registration 2018 must be met in line with the pending deadline of 31st May, 2018.

Discussion as to current UK base registrations are ongoing and much is being done to seek assurance that these will remain valid post departure. UK based registrations account for circa 17% of all current registrations.

Further to the general meeting I also took opportunity to meet with Gabrielle Edwards (Deputy Director of EU Environment at Defra) and also Dr Kay Williams (Head of EU and International Chemicals at Defra). I discussed the importance of chemicals supply, including exported & imported chemicals, to the plastics industry and ongoing domestic and international trade. Communication will continue as months proceed as to potential gains and impacts of future regulatory proposals in light of Brexit.

DecaBDE Flame Retardant

The restriction of use for DecaBDE flame retardant has entered the European Official Journal as approved by the EU Commission. This restriction states the following key aspects:
 

End of Update,
Thank you.

Steve Quinn, BPF Additive Suppliers Group Chair.