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

    Uploaded 16 May 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 16 May 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 16 May 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 26 Apr 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 26 Apr 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 07 Apr 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 21 Mar 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 17 Mar 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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  • FEICA Position Paper on the Registration of Polymers – the Exemption of Polyesters.pdf

    Uploaded 17 Mar 2022

    FEICA Position Paper on the Registration of Polymers – the Exemption of Polyesters

    FEICA published a paper supporting the polyesters exemption in the context of the registration of polymers. When defining polymers subject to registration, polymers without relevant toxicological or ecotoxicological properties will be considered as polymers of low concern (PLC) and exempt from registration obligations. The PLC concept would in principle apply to polyester polymers manufactured from predefined monomers under the so-called ’Polyester Exemption‘. The Polyester Exemption already exists in other jurisdictions such as the United States, Canada and Australia.

    Publication ref.: POP-EX-L03-017

    #REACH #polymers


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  • FEICA leaflet notification of polymers (Dutch).pdf

    Uploaded 09 Mar 2022

    Defining a system for the notification of polymers (DUTCH, in cooperation with VLK and DETIC)

    This is the Dutch translation of the original English leaflet which can be consulted here.

    The European Commission is working to extend registration requirements for polymers, currently exempted from registration under EU REACH. The Commission is considering requesting industry to notify of certain polymers’ information.

    This FEICA leaflet explains why the notification of polymers should be limited to a concise dataset and analytical or test data should not be required at the notification stage.

    Publication ref.: NL_FMI-EX-K10-052

    #REACH #polymers


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