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BiocidesFEICA position on the proposal for an EU Regulation concerning the placing on the market and use of Biocidal ProductsFEICA, the Association of European Adhesive & Sealant Manufacturers is a multinational association representing the European Adhesive and Sealant Industry. With the support of 14 national associations and 16 direct and affiliated members, FEICA coordinates, represents and advocates the common interests of our industry throughout Europe. In this regard FEICA aims at establishing a constructive dialogue with legislators in order to act as a reliable partner to resolve issues affecting the European Adhesive and Sealant Industry.
FEICA would, however, like to share several concerns regarding the proposed text as follows: We are concerned about the interactions and contradictions with other regulations such as REACH and CLP Regulations, and this requirement, as written, will complicate and confuse the end user, as products that are not hazardous under CLP Regulations, will be required to carry the full warnings for (several) concentrated biocidal products. Art. 47 - Placing on the market of treated articles or materials - In Article 47 of the draft regulation on biocidal products, no cut-off concentration is given for the reporting of biocides on the label of treated materials or articles. This would mean that even trace quantities of biocidal substances would have to be taken into account and would have to be reported on the label. This could for example be the case for residual biocidal substances from the production batch preceding the one in question. Trace quantities of biocidal substances may be detectable despite thorough purging of production lines and vessels. We therefore suggest to introduce cut-off values into Article 47 and aligning it with other legislation applicable to chemical substances and products such as REGULATION (EC) No 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) and Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures and subsequent amendments. More particularly, we suggest the use of specific concentration limits, generic concentration limits and M-factors set according to Article 10 and their values given in Annex VI, tables 3.1 and 3.2 of REGULATION (EC) No 1272/2008 and subsequent amendments. A second point of concern is that some adhesive articles are quite small with very limited label space. We therefore suggest to allow the use of INCI names (International Nomenclature for Cosmetic Ingredients) when reporting the biocidal substance on the label. This would have the advantage that only one language is required as INCI names are not language specific. INCI names are already used on cosmetic products and may be better known and understood by consumers. Alternatively, one could also consider establishing a numbering system such as it exists for food additives (E-numbers). Finally, if to avoid the burden of the new regulation manufacturers remove the biocidal products from their products, the net result will be an increase in spoilage and hence wastage. For example, if a supplier of adhesive to the food carton industry were to remove or reduce the amount of biocide needed to protect the sterility of the final dried film in contact with food; then the amount and type of bacteria/fungal contamination that will migrate into the foodstuff will be a significant problem, increasing the burden on recycling depots and landfill through disposal of items that have been spoilt through microbial attack, which potentially raises other more serious H&S concerns.
November 16th 2009 |
