ECHA announces public consultation of formaldehyde restriction in articles
The European Chemicals Agency (ECHA) has added new submitted restriction proposals, including that of formaldehyde and updated the status of these chemicals with regards to any ongoing public consultations.
The public consultation for the further restriction of formaldehyde commenced on 20th March 2019, with a submission deadline of 23:59 Helsinki time on 20th September 2019. Details and links to guidance on public consultations can be found in the section below.
ECHA submitted an Annex XV restriction proposal for the further restriction of formaldehyde in articles. This was in response to the learning outcomes from research carried out on behalf of ECHA. This research concluded that human health risks exist from the release of formaldehyde from consumer articles which are not adequately controlled in all scenarios.
Formaldehyde is a high production volume chemical with a wide array of uses. While formaldehyde is mostly used as a chemical intermediate and has limited applications as a biocide, substances manufactured from formaldehyde are used primarily in the production of articles.
Formaldehyde is used extensively in furniture articles, mainly in the form of urea formaldehyde (UF) resins, which are used in the production of particleboard and plywood. Formaldehyde can also be found in Phenol formaldehyde (PF) resins with application in the production of laminates, and in Melamine formaldehyde (MF) resins.
ECHA Consultation process and guidance
Interested parties wishing to participate in ECHA consultations can find a list of substances under public consultation; https://echa.europa.eu/restrictions-under-consideration
The formaldehyde consultation can be found at; https://comments.echa.europa.eu/comments_cms/AnnexXVRestrictionDossier.aspx?RObjectId=0b0236e18327d26e
ECHA offers guidance to those participating in consultations; https://echa.europa.eu/documents/10162/13641/public_consultation_guidance_en.pdf/7c4705d5-ad01-43ed-a611-06f1426a595c
Two deadlines are given in the summary table. The first deadline of 20th May 2019 is to allow ECHA to review early comments from the public consultation process.
The final deadline for comments is 20th September 2019, though ECHA state that comments submitted by the first deadline are often very influential as they will be considered in the first discussion on the proposed restriction and for most impact comments should be submitted at the latest 1 month before the final deadline.
The ECHA Committees will not take into account the comments received after the final deadline in their opinion making process.
Responsibilities under REACH
Under REACH regulations each actor in the supply chain bears responsibility for their articles’ safeness, especially if the articles contain substances that may have very serious effects on human health or the environment.
In order to ensure a high level of protection from the use of such substances in articles as regulated by REACH, the presence of SVHCs in articles needs to be transparent and communicated to all stakeholders in the supply chain. This is a prerequisite for the identification and application of appropriate risk management measures.
The identification of a substance as SVHC and its inclusion in the European Chemical Agency (ECHA) Candidate List is the first step of the authorisation procedure. Companies may have immediate legal obligations following such inclusion which are linked to the listed substance on its own, in preparations and articles.
Research Association members can access a recently published a REACH users guide which can be accessed at https://www.fira.co.uk/technical-information/environment/reach-guide
If you’re a producer, supplier or importer you have an obligation to understand your responsibilities regarding REACH. Whether it’s a small or larger part to play in the process, it is advisable to have an understanding according to your business activity.
Research Association members have access to news feeds, updates and technical articles regarding REACH. The technical services team can offer consultation and guidance regarding this subject to meet your needs. There is also a testing facility available via the Research Association's service provider FIRA International, to ensure that your products meet the REACH regulations.
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