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                            CONSUMER PRODUCTS AND RETAIL E-SSENTIALS

                            Your regular update for technical and industry information

                            Your regular update for technical and industry information

                            EU: POPs recast proposal brings PCP article restriction

                            may 2018 - Relevant for: Electrical & electronics, Hardlines, Softlines, Toys and Children's products INDUSTRY

                            The European Commission recently proposed to recast EU POPs Regulation (Persistent Organic Pollutants). This recast was to update the repealed regulatory procedures and align with the Lisbon Treaty; introduce the European Chemicals Agency (ECHA) to handle technical matters related to POPs Regulation. Most importantly, the Annexes of POPs is proposed to include new POPs from the Stockholm Convention. Pentachlorophenol and its salts and esters (PCP) may be restricted under Part A of Annex I of the POPs Regulation.

                            PCP has been widely used as biocides such as insecticides, herbicides and fungicides, etc. It also can be used in leather and wood preservatives. Owing to its high toxicity, PCP was substituted with other alternatives and its usage has decreased over decades. PCP can be found in textiles, leather, wood and paper in consumer products as residues. Articles containing PCP are regulated by various EU Member States including Germany, Austria and the Netherlands.

                            Although PCP is harmful to humans and the environment, no EU wide legislation regulates articles containing PCP. The EU POPs Regulation may be an appropriate measure to address the risks. Table A summarises the current and proposed PCP restriction in the EU.

                            In addition to PCP, polychlorinated naphthalene (PCN) and hexachlorobutadiene (HCBD) may be newly included in Part A of Annex I of the POPs Regulation. PCN is used for insulating coatings for electrical wires, additives in plastic and rubber and in lubricants. HCBD can be formed unintentionally during the production of some chlorinated hydrocarbons such as polyvinyl chloride.

                            Table A. Comparison of current and proposed PCP restriction in the EU

                            Reference

                            Substances

                            Mixtures

                            Articles

                            REACH Regulation, Annex XVII of entry 22

                            Not used

                            0.1% by weight

                            No requirement

                            POPs Regulation (Proposed)

                            Not used

                            Not used

                            Not used

                            1. POPs Recast – Draft Legal text
                            2. POPs Recast – Draft Annex

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