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British Rubber & Polyurethane Products Association



Posted on 15 April 2020

Even if the UK withdraws formally from the EU chemicals regulatory regime it will still operate in close conformity with the EU system for many years to come, so what happens on EU REACH will affect us for many years to come. It is important therefore to keep a close watch on what is happening over there. For recent developments at a general level read here:

  1. The European Commission has said it will publish a proposal by 2022 to bring “at least some” polymers under the REACH registration requirement. Polymers are currently exempt from registration or evaluation processes, although they are subject to authorisation or restriction if an EU member state chooses to include them in proposals.
  2. The European Commission has promised a new chemicals strategy for sustainability by the summer under a flagship environment programme – the Green Deal –, cementing a zero-pollution ambition for a toxic-free environment.
  3. The European Environment Agency (EEA) has said that the EU will miss major 2020 chemical policy objectives and forecasts and is expected to ‘lag behind’ in meeting the regulatory challenges of the next decade.


When it comes to specific materials read here:

  1. MbOCA: There has been no further information from European Commission regarding the pending formal decision on the MOCA authorisation application. EC was due to vote on the draft decision  by ECHA for authorisation for 4 year. At the time of writing, the latest information dated 20/03/2019 on the European Commission website stated that, Authorisation Decision was “Pending Adoption.”
  2. Titanium dioxide: After almost a decade of work the Commission has published its final decision to classify TiO2 as a category 2 carcinogen. Publication of the legislation comes after a lengthy and highly contested process which saw several unusual obstacles including member states reportedly tabling rare last minute objections during the two month scrutiny period. The delegated regulation entered into force after 20 days, with the harmonised classifications applying from September 2021.
  3. Siloxanes: Two European Chemicals Agency committees have supported the ECHA proposal to include D4 and D6 siloxanes – used as chemical intermediates in the production of a wide range of silicone materials including rubber – in the REACH candidate in the list of substances of very high concern. This was despite widespread criticism by industry of the move as disproportionate of such a move as disproportionate and unjustified and ignoring the performance and healthcare environmental benefits in healthcare, electronic and energy applications
  4. Cobalt: a 60-day public consultation on the proposed restriction on the draft restriction for the 5 cobalt salts of relevance for the rubber sector was initiated on 26 March.
  5. Resorcinol: This is predominantly used in the tyre industry and to a much smaller extent in the GRG sector. The Substance Evaluation Report compiled by Finland in 2017 did not identify it as an SVHC But the issue was open duo again at the bidding of the French in March 2019 and in March 2020 an Annex XV document was published suggesting that it should be considered for listing as an SVHC. An EU Resorcinol Task Force has been established and BRPPA will liaise with them to relay concerns to the HSE policy team, which feeds views into the ECHA risk assessment committees.