For third party submission of information on alternatives for Applications for Authorisation non-confidential Legal name of submitter(s)



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Submission of information on


Template

for third party submission of information on alternatives for

Applications for Authorisation

non-confidential

Legal name of submitter(s): International Chemical Secretariat

Norra Allégatan 5

SE-402 31 Gothenburg

Sweden
Table of CONTENTS

Submission of information on 1

1.alternative ID and properties 3

2.Technical feasibility 4

3.Economic feasibility 4

4.Hazards and risks of the alternative 4

5.Availability 4

6.Conclusion on suitability and availability of the Alternative 4

7.other comments 4

References 5

APPENDIXES 6




  1. alternative ID and properties


Alternatives to DEHP used in PVC include chemical alternatives to soften PVC as well as alternative plastic materials and other technical solutions where DEHP is not required.
Many downstream users have or are in the process of phasing out DEHP, many are also going further and phase out all phthalates or PVC material in general. This trend indicates there are different alternatives available and used already by a large number of companies in different sectors.

In 2010 ChemSec produced a report (Ref 9) which demonstrated that PVC had been removed from around 500 electronic product models on the market, including mobile phones, computers, washing machines, coffee machines and TVs. Products from 28 companies, among them Acer, Apple, Dell, HP, Nokia, Philips, Samsung and Sony Ericsson, were listed in the report. The same development is seen in many other businesses as well, e.g. the European Resilient Flooring Manufacturers Institute who has moved away from phthalates listed in Annex XIV in their products (Ref 10).

RIVM recently published a broad review (Ref 11) of alternatives to phthalates including DEHP. The alternatives are analysed in the report in terms of risks, technical and economic feasibility, suitability, availability and timing of substitution.
To further strengthen our arguments that alternatives are available and used in a broad range of sectors we have listed further relevant case stories below.


  1. Gemini Adhesives Ltd. has removed phthalates from their flexible cove former and capping strips by using the alternative plasticiser trioctyltrimellitate (TOTM). They have also managed to offer the product at a highly competitive price (Ref 1).




  1. Dell has a restriction for all products to the three phthalates DEHP, BBP, and DBP. These plasticisers have been replaced with Trioctyl trimellitate (TOM/TOTM) or Dioctyl terephthalate (DOTP), which offer the same functionality (Ref 2).




  1. Sustainable Cards has developed a wooden alternative to the use of PVC, PTEG or polystyrene in gift cards, key cards or access cards. The function of the wood cards is comparable to plastic cards and so is the duration time. The cards are compatible with most existing payment processing systems and hotel locking systems. They are also compliant with critical ISO standards. The cards are available in different colours and prints of the users choice (Ref 3).



  1. G-Star's has successfully replaced PVC and phthalates in High Density Plastisol prints by High Density Silicon prints. The substitution process is on-going in the global supply chain, in which the company works closely with suppliers, technicians and ink suppliers (Ref 4).





  1. DSM has phased out PVC by producing Stanyl® ForTii, a plastic free of halogens and plasticizers. The applications of the plastic are mainly in components for electronics, such as connectors and sockets. (Ref 5).




  1. DSM has phased out PVC by producing Arnitel® XG, a plastic free of halogens and plasticizers. The applications of the plastic are mainly in wires and cables intended for use in consumer electronics. (Ref 6).




  1. Shaw has substituted PVC carpet backing by EcoWorx, a material mixture of which the primary component is a food grade low density polyethylene (LDPE) (Ref 7).




  1. Nkt Cables has phased out PVC and developed the new cable type NOPOVIC® which is based on a mixture of halogen free polymers such as polyethylene (PE), polypropylene (PP) and ethylene-vinyl-acetate (EVA) copolymers with added non-flamable minerals like magnesium and aluminium hydrates (Ref 8).




  1. Skanska (world leading project development and construction group) took in year 2000 the decision ito phase-out PVC pipes and cables. This was done to avoid the risk of hydrochloric acid generation if a building catch fire since renovation costs are known to be higher where PVC is used. Today circa 90% of CDN (Commercial Development Nordic) buildings including 100% of its offices are halogen-free (Ref 12).
  2. Tarkett (flooring and sports surface solutions) has made a decision to only use phthalate-free plasticizers in its vinyl flooring production in Europe in 2014 (Ref 13).


  3. H&M list PVC on their restricted substance list meaning PVC is not used in H&M products (Ref 14).
  1. Technical feasibility


The fact that numerous companies have phased out DEHP (to another softener, by phasing out PVC or by using other techniques) shows a phase out is technically feasible. The fact that companies having made this are represented in numerous product segments, shows DEHP can be substituted in a large range of products and indicates that DEHP probably can be replaced in most products.
  1. Economic feasibility


The fact that numerous companies have phased out the use of DEHP shows that a phase out of DEHP is economically feasible.

  1. Hazards and risks of the alternative


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  1. Availability


The fact that numerous companies have phased out the use of DEHP shows that a alternatives are available, other softeners are available, other plastic material not requiring DEHP is available as well as other techniques are available.

  1. Conclusion on suitability and availability of the Alternative


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  1. other comments

We consider the handling of these first authorisation application as test case for future submissions and therefore call upon ECHA to take all the necessary steps to ensure that the process will be as effective and transparent as possible in order to deliver on the REACH objectives to substitute SVHCs by safer alternatives.

REACH article 60 (9) c, states that the authorisation shall specify the use(s) for which the authorisation is granted. This application on use of DEHP in PVC articles is very broad and lacks description of precise use; the application states more clearly where DEHP not will be found than the other way around. The aim for REACH is to give authorisation for specific uses where no alternatives are available and the chemical fulfil the requirements for adequate control or the socioeconomic route, not a general use of a SVHC substance which is what the applicant is asking for in this specific application.

This broad application also makes it very difficult to give precise information on chemical alternatives as well as technical alternatives. This also results in an extensive effort for stakeholders to provide input on all possible uses. ChemSec therefore regret this application has been approved by ECHA in the first place, not requiring a more specific application from the applicant.

According to the applicant there are alternative PVC plasticizers with lower hazard/risk profile than DEHP but since these can only replace a modest percentage of the applicant’s current DEHP sales, the applicant states that there are no suitable alternatives. The application does not contain a substitution plan due to this assumption; it is not within the remit of the applicant to decide on whether these alternatives are suitable or not, therefore a substitution plan must be developed.


Moreover, the approach on substitution should be on function, not on the substance. The applicant has restricted themselves to just look at chemical alternatives able to replace DEHP in all possible applications and not looked at different solutions for different applications, not considered other plastic material and not looked into other technical solutions where DEHP is not needed. This leads to a very narrow scope of available alternatives, which also is something we would have liked ECHA to highlight when processing the application.

According to REACH, the “appropriateness” or “suitability” assessment of the overall risks to human health/environment as well as the technical/economic feasibility of alternatives is to be evaluated by the European Commission, based on the opinions of the ECHA committees (see Art 60(5)). This is conceivable since an applicant has no obvious interest in highlighting that an existing alternative would be “suitable” to his particular use, since this would result in a refusal of his application for continued use of the SVHC subject to be phased out. Further any assessment of “suitability” is not to be done according to the subjective viewpoint of the applicant, but by the European Commission. It is clear according to Art 60(4) that this decision shall be taken AFTER consideration of all the elements (which includes the analysis of alternatives, substitution plan and third party contributions). In general it is the aim of the authorisation requirement that the applicant has to consider the technical and economic feasibility of substitution, including any research and development (see Art. 55 and recital 72).

The applicant has applied for authorization through adequate control route. According to REACH article 60(3a), the adequate control route shall not apply for substances meeting the criteria in CMR or article 57(f) for which it is not possible to determine a threshold in accordance with Section 6.4 of Annex I. DEHP has endocrine disrupting properties and since it is very doubtful that safe thresholds can be derived with sufficient certainty for EDCs adequate control route should not apply for DEHP.

The applicant states in it’s SEA that company profit as well as many jobs will be at risk if DEHP will not be authorised. This argument shows the unwillingness of these companies in finding other alternatives and work towards products with better environmental properties. A company producing DEHP can of course shift to produce other chemicals or other materials. It is understood that EU industry has already moved away from use of DEHP to a significant degree in recent years, due to the inclusion on the REACH candidate list and its CMR status (10). The later inclusion of DEHP to Annex XIV have of course not come as a surprise, the companies have had plenty of time to adjust its production and to find alternatives or alternative techniques to DEHP use.

References


  1. http://www.subsport.eu/case-stories/379-en?lang=en

  2. http://www.subsport.eu/case-stories/304-en?lang=en

  3. http://www.subsport.eu/case-stories/178-en?lang=

  4. http://www.subsport.eu/case-stories/371-en?lang=

  5. http://www.subsport.eu/case-stories/200-en?lang=

  6. http://www.subsport.eu/case-stories/084-en?lang=

  7. http://www.subsport.eu/case-stories/155-en?lang=

  8. http://www.subsport.eu/case-stories/039-en?lang=

  9. Electronics Without Brominated Flame retardants and PVC – a market Overview (http://www.chemsec.org/what-we-do/influencing-public-policy/rohs/alternatives-are-available)

  10. “The potential impact on industrial competitiveness of restrictions on certain CMR 1A and 1B substances in articles" - Scoping study for the application of art. 68.2 of REACH to CMR substances requiring priority action”. ICF International, Revised Ed 21 November 2013 (http://ec.europa.eu/enterprise/sectors/chemicals/files/docs_studies/final-report-cmr-1a-1b-in-art_en.pdf)

  11. Analysis of alternatives for a group of phthalates, Final Report. RIVM - Dutch National Institute for Public Health and the Environment & AMEC Environment & Infrastructure UK Limited. December 2013.

  12. http://www.group.skanska.com/Sustainability/Environmental-responsibility/Materials/Hazardous-Materials/

  13. http://www.tarkett.com/en/content/tarkett-announces-deployment-phthalate-free-technology


  14. http://about.hm.com/content/dam/hm/about/documents/en/CSR/Policies/HM%20Chemical%20Restrictions%20May%202013_Final%20w%20front_en.pdf


APPENDIXES

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0002-02, 0003-02, 0004-02

Date: 2013.12.??







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