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  • The 'one substance, one assessment' approach.pdf

    For members Uploaded June 13, 2022

    The ‘one substance, one assessment’ approach

    The current legal framework for chemicals’ risk assessment is extremely complex. Through the Chemicals Strategy for Sustainability, the Commission introduced the idea of the ‘one substance, one assessment’ process as a way to ensure that the initiation and priority setting of the safety assessments would be done in a co-ordinated, transparent and, to the extent possible, synchronised manner, taking into account the specificities of each sector.

    FEICA believes that risk management measures should not be a one-fits-all approach, as it would result in unjustified bans by declaring a product unsafe due to the lack of a specific risk assessment targeted to the respective application.

    This publication offers background information and FEICA’s view with regards to the concept of ‘one substance, one assessment’.

    Publication ref.: RAM-IN-K11-060

    #REACH #circulareconomy #sustainabledevelopment


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  • The ‘Essential Use’ Concept.pdf

    For members Uploaded June 13, 2022

    The ‘Essential Use’ Concept

    The ‘Essential Use’ Concept has been developed in the context of a global effort to regulate highly persistent substances in relation to their function in society. Its introduction could affect a myriad of substances, as it would allow a substance to be used only if critical to health and safety or critical for the functioning of society. It could bear substantial adjustment costs for the adhesives and sealants industry, forcing the sector to switch to alternative chemicals not necessarily providing the same technical performance.

    This publication offers background information with regards to the concept of ‘essential use’, FEICA’s view and the next steps.

    Publication ref.: RAM-IN-K10-056

    #REACH


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  • FEICA proposal for a list of starting monomers for the polyesters exemption.pdf

    Uploaded May 16, 2022

    FEICA Position Paper - FEICA proposal for a list of starting monomers for the polyesters exemption

    FEICA welcomes the European Commission’s proposal to keep an exemption for polyester polymers made from monomers on the EU list when polymers subject to registration requirements are defined. While FEICA considers the polyester exemption to be scientifically supported, we acknowledge that the list of starting monomers should be updated to eliminate hazardous monomers.

    This publication includes the FEICA proposal for a list as a starting point for the Commission and the European Chemicals Agency (ECHA) to develop an EU list of authorised monomers.

    Publication ref.: POP-EX-L05-028

    #REACH #polymers


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  • Why strictly controlled conditions cannot be technically applied to polymeric precursors.pdf

    Uploaded May 16, 2022

    FEICA Position Paper - Why strictly controlled conditions cannot be technically applied to polymeric precursors

    The European Commission proposed an exemption for polymeric precursors but only if they are handled as intermediates and strictly controlled conditions (SCC) are warranted along the supply chain. With this publication, FEICA would like to bring to the attention of the stakeholders why SCC cannot be applied to polymeric precursors used by downstream users.

    Publication ref.: POP-EX-L05-027

    #REACH #polymers


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  • Polymeric Precursors Examples.pdf

    Uploaded May 16, 2022

    Practical Application Examples to Demonstrate the Use of Polymeric Precursors

    Within the context of the registration of polymers, a potential exemption for polymeric precursors is under consideration. The European Commission is proposing an exemption for polymeric precursors handled like intermediates under REACH. This FEICA presentation provides 4 practical examples, demonstrating that polymeric precursors can be safely handled under adequately controlled conditions without causing harm to humans or the environment. The examples cover:

       1. One-Component Foam (OCF) - Industrial + Professional

       2. Direct Glazing (windshield bonding for cars) – Industrial + Professional

       3. Lamination of flexible substrates with reactive polyurethane (PU) adhesives – Industrial

       4. Liquid 2-component silicones for gasketing – Industrial

    Publication ref.: FMI-EX-L03-016

    #REACH #polymers


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  • FEICA response to the REACH revision public consultation 15 April 2022.pdf

    Uploaded April 26, 2022

    FEICA response to the REACH revision public consultation

    FEICA submitted its responses to the questionnaire in the public consultation. Here are some additional comments.

    #REACH #circulareconomy #sustainabledevelopment

    Publication ref.: POP-EX-L04-026


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  • FEICA contribution to the REACH revision public consultation 15 April 2022.pdf

    Uploaded April 26, 2022

    FEICA contribution to the REACH revision public consultation 

    As part of the ambition to reach zero pollution for a toxic-free environment established by the European Green Deal, the Chemicals Strategy for Sustainability announced the revision of Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).
    The European Commission has launched a public consultation allowing stakeholders to provide feedback on the proposed revisions. FEICA submitted its responses to the questionnaire in the public consultation. 

    #REACH #circulareconomy #sustainabledevelopment

    Publication ref.: POP-EX-L04-025 


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  • ASMoR Position Paper on the CARACAL paper CA/19/2022 on Generic Risk Approach.pdf

    Uploaded April 07, 2022

    FEICA co-signs ASMoR Position Paper on the CARACAL paper CA/19/2022 on Generic Risk Approach (GRA)

    ASMoR and its members hope that this submission will help the EU debates on the reform of chemical risk management and will make a significant contribution to the ongoing debate, particularly in the context of the GRA discussions.

    The Alliance for Sustainable Management of Chemical Risk (‘ASMoR’) is an alliance of more than 30 members that share a common position on the Essential Use Concept (‘EUC’) in EU chemicals policy.

    Publication ref.: COS-EX-L04-022

    #REACH #sustainabledevelopment #hazardousproducts


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  • FEICA position on the MAF.pdf

    Uploaded March 21, 2022

    FEICA Position Paper on the Mixture Assessment Factor (MAF)

    Under the Chemical Strategy for Sustainability, the European Commission plans to put a system in place that covers the combination effects of unintentional chemical mixtures. Because of the complexity linked to regulating an almost infinite number of possible combinations of chemicals, the concept of a Mixture Assessment Factor (MAF) was launched. This position paper discusses FEICA’s view that the introduction of a MAF should be risk-proportionate, workable and effective.

    Publication ref.: POP-EX-L03-019

    #REACH


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  • FEICA Position Paper - FEICA comments after 7th CASG polymers meeting.pdf

    Uploaded March 17, 2022

    FEICA comments after 7th CASG polymers meeting

    FEICA participated in the 7th CARACAL Subgroup polymers meeting held on 23 February 2022. With this paper, FEICA submits follow-up comments about the notification, grouping and naming of polymers.

    Publication ref.: POP-EX-L03-018

    #REACH #polymers


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